Other View taken by Assessing Officer with application of mind even if prejudicial to interests of Revenue does not allow CIT to initiate proceedings u/s 263

 Brief Facts of the case: Mr. Sanka Venkata Rama Rao, is an Individual derives income from business of money lending on hypothecation of gold/silver articles A survey u/s 133A was carried at the premises of the assessee by the department and consequent to survey, the assessee filed his return of income for assessment year 2010-11 on 30.09.2011 admitting a total income of Rs.30,23,250. The scrutiny assessment was completed on 18./04.2011 determining the total income at Rs. 53,59,650.The records of the assessment proceedings were examined by the Commissioner of Income Tax who observed that ther...