2025 (4) TMI 1884

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....e Respondent : Shri R. Clement Ramesh Kumar, CIT ORDER PER JAGADISH, A.M : This appeal filed by the assessee is directed against the order of the Principal Commissioner of Income Tax (Central)-1, Chennai dated 24.03.2024 relevant to the assessment year 2020-21 passed u/s. 263 of the Income-tax Act, 1961 (hereinafter "the Act"). 2. There is a delay of 36 days in filing the appeal by the....

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....uring the survey operation. Subsequently, the assessee filed return of income on 31.12.2020 declaring total income of Rs. 14,04,930/-. The A.O in the assessment order passed u/s. 143(3) of the Act has noted that the assessee has furnished details regarding additional income offered and as per the details furnished by the assessee, the additional income admitted during the survey has been offered i....

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....s/verification to find out whether the excess stock estimated during the survey is included in the total return. 5. The Ld. Authorized Representative (A.R) of the assessee before us has submitted that survey was conducted on 25.02.2020 before the end of financial year and the assessee in the return of income filled has shown total income of Rs. 14,04,930/-, which included the income disclosed d....

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....-. In the assessment order, the A.O noted that the additional income admitted during the survey has been offered in the return of income. However, the Ld. PCIT has observed that the A.O had not verified whether the stock admitted during the course of survey was actually included in the return of income and held the assessment order passed by the A.O u/s 143(3) of the Act as erroneous and prejudici....