Proceedings u/s 263 sustained as AO failed to apply proper and correct section of Income Tax Act

Saitawadekar Jewellers Vs CIT (ITAT Pune) ITAT Pune held that revisionary proceedings under section 263 sustained as AO failed to apply proper and correct section of Income Tax Act to the investment in the undisclosed stock. Facts- The assessee’s case was selected for scrutiny assessment. The assessment order u/s 143(3) for AY 2015-16 was passed on27/11/2017 accepting the returned income. The Pr.CIT Pune after verification of records issued notice u/s.263 dated 16/2/2021 and then passed order u/s 263 dated 18/03/2021. This order was challenged by the Assessee before the ITAT. The ITAT in ITA...