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Income Tax Appellate Tribunal, RANCHI BENCH “E” Court at KOLKATA
Before: Shri S.S.Godara & Dr. A.L. Saini
O R D E R PER BENCH (Oral):- This assessee’s appeal for assessment year 2010-11 arises against the Commissioner of Income Tax (Appeals)-Hazaribagh’s order dated 09.05.2018 passed in case No.10028/HZB/2017-18, involving proceedings u/s 147 r.w.s. 143(3) the Income Tax Act, 1961; in short ‘the Act’. Heard both the parties. Case file perused.
It transpires at the outset that the Assessing Officer had initiated section 148 r.w.s. 147 proceedings against the assessee as per the notice dated 24.03.2017 after recording the following reasons:- “It has been observed that the assessee has debited Rs.14,72,991/- in the P/L account under the sub-head ‘Revenue’. It is quite evident from the record that the expenditure made under this sub-head is not revenue expenditure and hence books of account are required to be examined. It is a sort of recovery against revenue (i.e.