TaxTMI 
TaxTMI 
2025 (3) TMI 2310
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....se, the assessment under Section 147 r.w.s. 144B of the Act was passed on 24/09/2021. In the assessment order it has been mentioned that the assessee had made cash deposits of Rs. 4,18,39,194/- in his bank account maintained with United Bank of India, Ranchi during the F.Y. 2012-13. On the basis of such information, the case of assessee was reopened under Section 147 of the Act after recording reasons and getting approval from the competent authority, notice under Section 148 of the Act was issued to the assessee on 13/03/2020. In response to that, the assessee filed its return of income on 19/03/2020 declaring loss of Rs. 26,32,390/-. Statutory notices under Section 142(1) and 143(2) of the Act were issued to the assessee from time to time....
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....t in initiating revision proceeding based on his opinion and start fishing and roving inquiries in matters or orders which are already concluded. 4. The ld. PCIT, even in the notice u/s 263 has not specifically brought on record under the given facts and circumstances why the assessment order is erroneous or what enquiry was not done by the Assessing Officer (NFAC) so as to be prejudicial to the interest of the Revenue when on the contrary all the facts were scrutinized by the Assessing Officer (NFAC) and he has arrived at a plausible opinion on the application of mind. 5. The Ld. PCIT erred in not accepting the fact that, where the claim was allowed by the AO after raining queries and on being satisfied with the explanati....
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....00 7 02.05.2012 9,64,387 8 02.05.2012 10,000 9 03.05.2012 5,00,000 10 05.05.2012 4,00,000 11 09.05.2012 15,500 12 14.05.2012 8,000 13 19.05.2012 9,50,000 14 22.05.2012 9,50,000 15 23.05.2012 7,25,000 16 11.06.2012 9,50,000 17 15.06.2012 9,50,000 18 18.06.2012 9150,000 19 20.06.2012 10,000 20 02.07.2012 10,000 21 09.07.2012 6,00,000 22 10.07.2012 6,75,730 23 11.07.2012 100, 000 24 23.07.2012 9,50,000 25 27.07.2012 9,50,000 26 14.08.2012 9,50,000 27 17.09,2012 9,00,000 28 10.10,2012 2,93,000 29 22.11.2012 5,00,000 30 10.12.2012 11....
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....eceived for escapement of income on 13/03/2020 based on the AIR information regarding the deposit of cash in the Bank account of the firm and deduction of TDS on Commission and Rent during the Assessment Year. In compliance with the notice U/s 148 return was filed on 19/03/2020. The Reason as communicated to us for the escapement of income was "The assessee failed to file its return of Income. An aggregate amount of Rs. 41839194/- was deposited in cash into the assessee's bank account. TDS was made u/s 194H out of the payments to the assessee by Bharat Sanchar Nigam Ltd. TDM, Dumka. From the TDS data, it is evident that an aggregate amount of Rs. 705980/- was paid towards commission or brokerage to the assessee by Bharat Sancha....
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....of the assessee is accepted and no addition is made on the above-mentioned issues. Therefore, the returned income of the assessee was accepted by the Assessing Officer at the National Faceless Assessment Centre Delhi. On the receipt of the order, the assessee made an application to the Assessing officer for the withdrawal of the prosecution case u/s 276CC for not filing of return of Income filed in 2017. The assessing officer sent the letter to the standing counsel of the department for his opinion on 06/09/2022 and the same was sent to PCIT, Dhanbad for direction. Copy enclosed at the page. Show Cause notice U/s of 263 of the I. T. Act, 1961 for the A.Y. 2013-14 against order u/s 147 r.w.s 143(3) dated 16/11/2022 was rece....