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Section 263 Jurisdiction Fails – AO’s Plausible View in Search Cases Upheld
Case Law Details
- Case Name
- Zari Silk (India) Pvt. Ltd. Vs. PCIT (ITAT Jaipur)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2021-22
- Courts
- All ITAT, ITAT Jaipur
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Zari Silk (India) Pvt. Ltd. Vs. PCIT (ITAT Jaipur)
Facts
A search u/s 132 was conducted on 23.11.2021 at the premises of Zari Silk (India) Pvt. Ltd. & its director, Shri Arun Palawat. Assessees filed returns declaring losses. AO completed assessments u/s 143(3) r.w.s. 148B after detailed enquiry, making additions of ₹33.90 lakh (company) & ₹88.24 lakh (individual) as “income from other sources”. Orders were passed with prior approval of Addl. CIT u/s 148B. Later, PCIT (Central) invoked revisionary powers u/s 263 on the ground that AO should have assessed such amounts u/s 69A/...
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