2025 (4) TMI 1924

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....6.02.2019 for Assessment Year 2014-15. ITA No. 83/Pat/2023 filed by the assessee against the order of the Ld. CIT(A), NFAC, Delhi vide order dated 20.02.2023 for AY 2014-15 confirming the assessment order passed as a consequence of the order passed u/s. 263 of the Act. 2. Shri K. N. Prasad, Advocate & Shri Vishal Kr. Advocate represented on behalf of the assessee and Shri Ashwani Kr. Singal, JCIT, DR appeared on behalf of the revenue. 3. It was submitted by the Ld. AR that the original assessment in the case of the assessee came to be completed on 31.08.2016 u/s. 143(3) of the Act. It was the submission that this was a limited scrutiny assessment for verification in respect of the large cash deposits in the savings bank account. It wa....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nt that the submissions of the assessee in this respect was examined and found no adverse inference. It was the submission that this was not a speaking order. It was the submission that this was a case of inadequate enquiry. It was the submission that more than inadequate enquiry this was practically an assessment done without examining any of the details provided by the assessee. It was the submission that the order u/s. 263 is liable to be upheld. 5. We have considered the rival submissions. It would be worthwhile to extract the order of the Ld. Pr. CIT-1, Kolkata for better understanding the facts in the present case, the same reads as follows: "In the instant case order u/s 143(3) of the Income Tax Act, 1961, dated 31/08/201....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....rd." 6. A perusal of the order of the Ld. Pr. CIT clearly shows that he has not found any error much less an error which has caused prejudice to the interest of the revenue. The original assessment order was a limited scrutiny assessment for verification of large cash deposits. A perusal of the order sheet entry clearly shows that the Assessing Officer has called for the details and has examined the same. Admittedly, in the assessment order, the AO has mentioned that the submissions of the assessee in this regard were examined and no adverse inference was found. Part of the explanation of the assessee has also been extracted by the Assessing Officer in the original assessment order. These explanations of the assessee have not been found ....