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INCOME TAX APPELLATE TRIBUNAL (RAJKOT BENCH)
DR. ARJUN LAL SAINI, ACM, SHRI DINESH MOHAN SINHA, JM
SIMERO VITRIFIED (P.) Ltd. – Appellant
Versus
The Pr. CIT - 3 – Respondent
| Table of Content |
|---|
| 1. challenge to order under section 263. (Para 3) |
| 2. assessment of company losses. (Para 4) |
| 3. failure to verify share capital authenticity. (Para 5 , 6 , 7) |
| 4. principles for authorizing section 263 revisions. (Para 8 , 9) |
| 5. assessment order's imperfections necessitating revision. (Para 10 , 11) |
| 6. arguments presented by the assessee. (Para 12 , 13 , 14 , 15 , 16) |
| 7. ruling on opportunity for resubmission of documents. (Para 18 , 19) |
| 8. final decision to allow the appeal for reassessment. (Para 20 , 21) |
ORDER
Per Bench:
By way of this appeal, the assessee has challenged the correctness of the order dated 13.08.2019, passed by the Learned Principal Commissioner of Income-tax (in short “Ld PCIT”) under section 263 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), for the assessment year 2016-17.
2 .Grievances raised by the assessee, which, being interconnected, will be taken up together, are as follows:
1.The order u/s. 263 of the Act is bad in law.
2.The Learned Pr. CIT has erred in law as well as on facts in not considering the submission of the appellant that the order passed by the AO u/s. 143(3) was either erroneous nor prejudicial to the interest of reven
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