A mere diference is perception of CIT & AO cannot make the order erroneous & prejudicial to the interest or revenue

CA Prarthana Jalan We have heard the rival contentions, material available on the record and case laws cited by both the parties. From the facts narrated above and the paper books filed it emerges that during the course of assessment proceeding questions, enquiries and explanation on the relevant issues were called for by the ld AO and were replied by the assessee. Thus these are not the assessments where there was no enquiry on the relevant aspect. The questionnaires, order sheet entries, assessees submissions and explanations make it quite clear. Thus we are unable to hold that assessment ...