2025 (3) TMI 2306

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....(AY) 2017-18 by raising following grounds of appeal: "1. That the Ld. PCIT erred in law and in fact in setting aside the order of the Ld. AO under Section 143(3) by invoking revisionary jurisdiction under section 263. 2. That the Ld. PCIT erred in invoking revisionary jurisdiction under section 263 on the basis of a proposal sent to him without suo motu calling for and examining the record of assessment. 3. That the Ld. PCIT erred in concluding the assessment order to be erroneous with respect to truck expenses of INR 9,62,826/- when all the necessary records and proofs thereof was submitted before him by simply observing that no records were submitted. 4. That the Ld. PCIT erred in directing the AO to ma....

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....spect of 'truck expenses' and 'unsecured loans' on the grounds that the Assessing Officer has failed to verify the same without conducting any enquiry and therefore, the assessment order passed under Section 143(3) of the Act was erroneous and prejudicial to the interests of revenue. 3. Aggrieved by the order under Section 263 of the Act dated 03/03/2022, the appellant has raised the above grounds of appeal. During the course of hearing before us, it was submitted by the appellant that the ld. PCIT has erred in assuming jurisdiction under Section 263 of the Act without taking suo motu cognizance and without calling and examining the assessment record and claimed that all necessary documents and evidences regarding the tru....