2025 (3) TMI 2043

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....f appeal, but her grievance revolves around a single issue namely, ld. CIT has erred in taking cognizance under Section 263 of the Income Tax Act and thereby setting aside the assessment order passed under Section 147 read with Section 144B of the Income Tax Act. 3. The brief facts of the case are that assessee did not file her return of income. The AO armed with information that assessee had made deposits in her Canara Bank account, reopened the assessment. He ultimately made an addition of Rs. 98,26,659/- in an assessment order passed under Section 147 read with Section 144B on 24.03.2022. 4. The ld. CIT harboured a belief that assessment order is erroneous as much as it caused prejudice to the interests of the Revenue. He was of th....

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....ate from the Registrar of Himachal Pradesh High Court, which is available at page 5 of the Paper Book. This certificate demonstrate that a sum of Rs. 98,26,659/- was transmitted to the SB Account with Canara Bank by the Hon'ble High Court which represents the enhanced compensation awarded to the assessee on compulsory land acquisition. The certificate reads as under: TO WHOM IT MAY CONCERN It is certified that a sum of Rs. 98,26,659/- was transferred in the Canara Bank Savings Account Number 2066101041 174 of Smt. Saroj Bala by H. P. High Court Shimia on 7.10.2016 through State Bank of Patiala, Shimla-East. This amount being enhanced compensation/award amount was earlier deposited in H.P. High Court Shimia, by the CEO-cum-Se....