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“erroneous and prejudicial”

Rectification & RevisionSection 263Section 2633,136 judgments

The decision most relied on for erroneous and prejudicial is Malabar Industrial Co. Ltd. v. CIT (243 ITR 83), cited in 2,943 judgments on BharatTax.

Leading authorities on erroneous and prejudicial

Malabar Industrial Co. Ltd. v. CIT
243 ITR 83 · 2000 · Supreme Court
2,943
citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

CIT v. Max India Ltd.
295 ITR 282 · 2007 · Supreme Court
1,162
citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

CIT v. Gabriel India Ltd.
203 ITR 108 · 1993 · High Court
990
citing judgments

The Commissioner cannot revise an assessment order under Section 263 merely because they hold a different opinion or believe a deeper inquiry was warranted if the Assessing Officer has applied their mind and conducted some inquiry. Revision under Section 263 is permissible only in cases of a complete lack of inquiry or non-application of mind by the Assessing Officer, not for merely inadequate inquiry.

CIT v. Sunbeam Auto Ltd.
332 ITR 167 · 2011 · High Court
897
citing judgments

The Commissioner cannot revise an assessment under Section 263 merely because the assessment order does not explicitly reflect an inquiry, or because the Commissioner holds a different opinion. An inquiry, even if considered inadequate, or an assessment based on a plausible view by the Assessing Officer after due examination, does not automatically make the order erroneous or prejudicial to the interests of the revenue.

Rampyari Devi Saraogi v. CIT
67 ITR 84 · 1968 · Supreme Court
616
citing judgments

An assessment order is erroneous and prejudicial to the Revenue's interests if the Assessing Officer accepts a sum offered as income by an assessee, even when that sum was not actually earned, thereby allowing revision under Section 263.

Gee Vee Enterprises v. Addl. CIT
99 ITR 375 · 1975 · High Court
543
citing judgments

An assessment order is erroneous and prejudicial to the interest of revenue if the Assessing Officer fails to make proper inquiries before accepting the assessee's statements or claims. The Commissioner can revise such an order under Section 263 without conducting further inquiries himself.

ITO v. D.G. Housing Projects Ltd.
343 ITR 329 · 2012 · High Court
438
citing judgments

For exercising revisional jurisdiction under Section 263, the Commissioner must first find that the Assessing Officer's order is erroneous and unsustainable in law, as this is a condition precedent. An order is not erroneous merely because two views are possible, or if the Commissioner disagrees with the Assessing Officer's permissible view, or to simply remit the matter for further enquiries.

CIT v. Vikas Polymers
341 ITR 537 · 2012 · High Court
318
citing judgments

An assessment order is not erroneous and prejudicial under Section 263 merely because the Assessing Officer did not record an enquiry and its satisfactory answer in the assessment order, provided such an enquiry was conducted. For revision under Section 263, the Commissioner must also provide the assessee an opportunity of being heard and examine their explanation.

Judgments citing erroneous and prejudicial

Sarang Trade Links, Muzaffarnagar vs. Pr, CIT, Dehradun

ITA 473/DEL/2021[2015-16]Status: DisposedITAT Delhi14 Aug 2024AY 2015-16

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Pareekita No:- 473/Del/2021 (Assessment Year- 2015-16)

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Sapna Bhatia CIT(DR)
Section 133(6)Section 143(3)Section 263

submitted that the PCIT has imposed unnecessary inquiries by reopening the completed assessment u/s 263 of the Act without the assessment year being erroneous and prejudicial to the interest of revenue. The Ld. Counsel thus urges for the cancellation of the revisional order

Shri Amjad Ahmed Sheikh, Nagpur vs. Principal Commissioner of Income Tax-2, Nagpur

In the result, appeal filed by the assessee is dismissed

ITA 18/NAG/2021[2014-15]Status: DisposedITAT Nagpur13 Aug 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rachit ThakarFor Respondent: Shri Kailash C. Kanojiya
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 263

raised following grounds:– “1] Assessment order passed by learned A.O. U/s.143(3) r.w.s. 147 dt.19.12.2018 after considering all the facts was neither erroneous nor prejudicial to the interest of revenue and hence learned C.I.T. has no jurisdiction U/s.263 of I.T.Act, 1961 to revise the order. Thus the impugned order ... sale of another property appearing on ITS, all these aspects should have been verified by the AO. Accordingly, it has to be considered erroneous and prejudicial to the interest of revenue. 6.4 to 6.10 …………… 7. In the light of facts mentioned in the foregoing paras and the details on record

DCIT 14.1.1, Mumbai vs. Aadi Industries Ltd, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 3215/MUM/2024[2010-11]Status: DisposedITAT Mumbai13 Aug 2024AY 2010-11

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawaldcit – 14(1)(1), Vs. M/S.Aadi Industries Ltd 320/7, Siddhivinayak Room No. 432, 4Th Floor Housing Society, Aayakar Bhavan, Hingwals Lane, M.K.Road, Ghatkopar (East), Mumbai -400020. Mumbai – 400075. Pan/Gir No. Aaacj8256G (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By Shri Manoj Kumar Sinha, Sr. Dr Respondent By None सुनवाई क" तार"ख/Date Of Hearing 07.08.2024 घोषणा क" तार"ख/Date Of Pronouncement 12.08.2024 Order Per Pavan Kumar Gadale, Jm: “ The Appeal Is Filed By The Revenue Against The Order Of National Faceless Appeal Centre(Nfac), Delhi / Cit(A) Passed U/Sec143(3) R.W.S263 U/Sec 250 Of The Act. The Revenue Has Raised The Following Grounds Of Appeal:

Section 143(3)

perusal of the record and information found that the order passed by the AO u/sec 143(3) r.w.s 147 of the Act is erroneous and prejudicial to the interest of the revenue and has issued directions to the AO vide order u/sec 263 of the Act dated 17.03.2020. In compliance

Mylan Laboratories Limited, Hyderabad vs. Deputy Commissioner Income Tax, Circle-5 (1), Hyderabad

In the result, the ground no

ITA 206/HYD/2021[2014-15]Status: DisposedITAT Hyderabad12 Aug 2024AY 2014-15

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Shri Kumar Pranav, CIT-DR
Section 263Section 37

passed by the Ld.AO with a direction to redo the assessment without appreciating the fact that the assessment order of Ld.AO is not erroneous and/or prejudicial to the interest of the revenue. 4. Without prejudice to the above, on the facts and in the circumstances of the case ... held that a mere audit objection cannot lead to an inference that the order of the Assessing Officer was erroneous or prejudicial to the interest of the Revenue, where there was no indication that the Commissioner notes was himself satisfied about it prior to issue of notice, so that

M/S. R.K. Investments, Chennai vs. DCIT, Ncc-3(1), Chennai

The appeal stand allowed in terms of our above order

ITA 1159/CHNY/2024[2014-15]Status: DisposedITAT Chennai12 Aug 2024AY 2014-15

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1159/Chny/2024 (िनधा*रणवष* / Assessment Year: 2014-15) M/S. R.K. Investments Dcit Ground Floor, Block-Iv, Non-Corporate Circle-3(1) बनाम/ No.184-187,Temple Steps, Chennai. Vs. Anna Salai Little Mount, Chennai-600 015. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaafr-3413-Q (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Vijayaraghavan (Advocate)-Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 31-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 12-08-2024 आदेश / O R D E R

For Appellant: Shri R. Vijayaraghavan (Advocate)-Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -Ld. DR
Section 143(3)Section 147Section 148Section 2(14)Section 2(14)(iii)Section 2(14)(lii)Section 263Section 45

last preceding census. Finally, considering Explanation-2 to Sec. 263, the assessment order dated 28-03-2022 was held to be erroneous and prejudicial to the interests of revenue. Accordingly, the order was set aside with a direction to Ld. AO to make necessary enquiries on the aforesaid lines

Dasrathsinh Ghanshyamsinh Chudasama, Bhavnagar vs. The Pr. Commissioner of Income-Tax-6, Ahmedabad

In the result, appeal of the assessee is allowed

ITA 223/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad08 Aug 2024AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2015-16

Section 115BSection 143(1)Section 143(2)Section 263Section 68

cause notice of the PCIT issued under Section 263 of the Act did not categorically give the finding that the Assessment Order is erroneous and prejudicial. The Ld. AR submitted that the notice issued is vague and factually incorrect and does not categorically conclude that the Assessment Order is erroneous ... PCIT to be inconclusive. The Ld. AR further submitted that the PCIT has to be absolutely clear that the order is both erroneous and prejudicial at the time of the issue of notice. In absence of this unequivocal conclusion the exercise opens doors of review of the earlier order passed

Suresh Kantilal Thakkar, Banaskantha vs. The PCIT, Ahmedabad-3, Ahmedabad

In the result, the appeal of the assessee is dismissed and the Assessing

ITA 1025/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad07 Aug 2024AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Shri Bhavik Nagori, A.RFor Respondent: Shri Kamlesh Makwana, CIT DR
Section 147Section 263Section 69A

submissions of the assessee on record set-aside the assessment order as being Suresh Kantilal Thakkar vs. PCIT Asst.Year –2016-17 - 3– erroneous and prejudicial to the interest of the Revenue with the following observations: “13. In view of the detailed discussions above and the legal position laid down ... various Courts, it is sufficient to draw a conclusion that the Order passed by the AO is erroneous and prejudicial to the interest of revenue. In this case, the assessee had claimed STCL of Rs. 3,75,14,478/- from sale of shares of ECL. As discussed in foregoing paragraphs

M/S. P Praful & Co Agency(India)Pvt. Ltd, Ahmedabad vs. Pr. CIT-3, Ahmedabad

In the result, the appeal filed by the Assessee is dismissed

ITA 528/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad07 Aug 2024AY 2014-15

Bench: Final Appeal.

Section 127Section 143(3)

illegal. 3. The Ld. Pr.CIT has erred in law and on facts in considering that order passed by Ld. A.O. as erroneous and prejudicial to the interest of revenue. 4. The appellant craves liberty to add, amend, alter or modify all or any grounds of appeal before final appeal

Dic Fine Chemicals Pvt. Ltd., Kolkata vs. P.C.I.T. - 2, Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 1075/KOL/2024[2017-2018]Status: DisposedITAT Kolkata07 Aug 2024AY 2017-2018

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 142(1)Section 143(3)Section 263

facts in revising the assessment order u/s 143(3) of the Act dated 27.04.2021 even though the said order was neither erroneous nor prejudicial to the interest of the Revenue for the reasons set out in the show cause notice. 2. For that on the facts and in the circumstances ... original assessment completed u/s 143(3) of the Act and therefore the order of the AO could not be held to be erroneous and prejudicial to the interests of the Revenue. 3. For that on the facts and in the circumstances of the case and in law, the assessee having

Guardian India Operations Private Limited, Chennai vs. PCIT 1, Chennai

In the result, the appeal filed by the assessee is dismissed

ITA 842/CHNY/2024[2017-18]Status: DisposedITAT Chennai07 Aug 2024AY 2017-18

Bench: HON’BLE SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

For Appellant: Shri. Ashik ShahFor Respondent: Shri. V. Nandakumar, IRS,CIT
Section 143(1)Section 143(2)Section 143(3)Section 263

passed the assessment order dated April 21, 2021, after making proper enquiries and verification of records and therefore, the said order is neither erroneous nor prejudicial to the interest of the revenue and hence the impugned order passed by the Ld. PCTT is liable to be quashed. 2.2. The order ... considered opinion that order of AO dated 21.04.2021 passed u/s 143(3) r.w. section 144B of the Act is erroneous and prejudicial to the interest of revenue. Hence, we find no infirmity in the impugned order of ld.PCIT revising the order of AO dated 21.04.2021 passed

The Pondicherry State Co-Operative Consumers Federation Ltd, Pondicherry vs. PCIT-3, Chennai

In the result, the appeal filed by the assessee is allowed

ITA 1298/CHNY/2024[2018-19]Status: DisposedITAT Chennai07 Aug 2024AY 2018-19

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri M. Karunakaran, AdvocateFor Respondent: Shri Nilay Baran Som, CIT
Section 142(1)Section 143(3)Section 144Section 263Section 270ASection 80P

According to PCIT, hence the assessment order passed u/s.143(3) r.w.s 144B of the Act dated 17.04.2021 by the Faceless Assessing Officer is erroneous and prejudicial to the interest of Revenue in term of clause (a) of Explanation 2 to section 263(1) of the Act. He required the assessee ... explain as to why the assessment order passed should not be set aside by treating the same as erroneous and prejudicial to the interest of Revenue. The show cause notice is dated 28.07.2023. The assessee furnished reply and given complete details of sundry creditors which consists of statutory liabilities like

Sumit Niranjankumar Shah, Mumbai vs. CIT (It)-4, Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 2564/MUM/2024[2018-19]Status: DisposedITAT Mumbai07 Aug 2024AY 2018-19

Bench: Shri B R Baskaran, Hon’Ble & Shri Anikesh Banerjee, Hon’Blesumit Niranjankumar Shah Cit (It)-4, Mumbai A-1101, Quantum Park, Near Union Bank, Gulab Nagar, Khar (West), Mumbai 400 052. Pan Aahps1841E (Appellant) (Respondent)

For Appellant: Shri Anuj KisnadwalaFor Respondent: Ms. Madhu Malati Ghosh (CIT. DR)
Section 23Section 24Section 263

Value in respect of one of the properties. Accordingly, he 2 Sumit Niranjankumar Shah took the view that the assessment order is rendered erroneous and prejudicial to the interests of revenue. Accordingly, he initiated revision proceedings u/s 263 of the Act. After hearing the assessee, the Ld CIT set aside

Nirav Chandrakantbhai Bhalani, Bhavnagar vs. The Pr. CIT, Ahmedabad-1, Ahmedabad

In the result, the appeal of the Assessee is partly allowed

ITA 1041/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad06 Aug 2024AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1041/Ahd/2024 "नधा"रण वष" /Assessment Year :2016-17 Nirav Chandrakantbhai The Pr.Cit,Ahmedabad-1 Bhalani बनाम/ Ahmedabad-380 015 Plot No.9, Vibhapark Society V/S. Adhewada, Bhavnagar Bhavnagar – 364 002 (Gujarat) "थायी लेखा सं./Pan: Bcipb 8197 E (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Shri Kamlesh Makwana, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 29/07/2024 घोषणा क" तार"ख /Date Of Pronouncement: 06/08/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Dated 27/03/2024 Passed By The Principal Commissioner Of Income Tax, Ahmedabad-1 [Hereinafter Referred To As “The Ld.Pcit” In Short] In Exercise Of His Revisionary Jurisdiction Under Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act” In Short) For The Assessment Year (Ay) 2016-17. Nirav Chandrakantbhai Bhalani Vs. The Pcit Asst. Year : 2016-17

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Shri Kamlesh Makwana, CIT-DR
Section 142(1)Section 144Section 147Section 148Section 263Section 68

Section 263 of the Act empowers the Ld.PCIT to revise any order passed by the AO if it is erroneous and prejudicial to the interests of the revenue. An order can be considered erroneous if it is passed without proper verification, inquiry, or based on incorrect facts ... legally unsustainable, the notice can be challenged as invalid. The Ld.PCIT must have sufficient evidence to support the claim that the order is erroneous and prejudicial to the interests of the revenue. Mere suspicion or conjecture is not sufficient. 6.5. Based on the detailed analysis of the facts and judicial

Kohinoor Ctnl Infrastructure Co. Private Limited, Dadar West vs. Dy Commissioner of Income Tax 6(1)(2), Churchgate Mumbai

In the result, the appeal is dismissed

ITA 1962/MUM/2024[2018-19]Status: DisposedITAT Mumbai06 Aug 2024AY 2018-19

Bench: Shri Narender Kumar Chaoudhry & Shri Ratnesh Nandan Sahay

For Appellant: Shri Jayesh Dadia, A.RFor Respondent: Shri Biswanath Das- CIT D.R
Section 143(1)Section 143(3)Section 250Section 263

assessment. This renders the assessment order dated 16/04/2021 passed u/s. 143(3) of the Act for the assessment year 2018-19 as erroneous and prejudicial to the interest of revenue. . While passing order u/s. 263 of the Act, the Ld. PCIT placed reliance on following decisions ... possible and the Income Tax Officer has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the interests of the Revenue unless the view taken by the Income Tax Officer is unsustainable in law. It has = Page |10 Kohinoor

Jaipur Engineering College Jaipur Rajasthan Society, Jaipur vs. Circle (Exemption), Jaipur

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 261/JPR/2024[2017-18]Status: DisposedITAT Jaipur05 Aug 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P. C. Parwal (C.A.)For Respondent: Shri A.S. Nehra (Addl.CIT)
Section 11Section 13(1)(c)Section 13(3)Section 164(2)

Commissioner of Income Tax, after verification of the records of the Assessing Officer found that the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the revenue. Accordingly, he initiated the proceedings under section 263 of the Act. The Commissioner was of the opinion that

Mahesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-2(2)(1), Bangalore

ITA 936/BANG/2024[2018-19]Status: DisposedITAT Bangalore05 Aug 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Soundararajan K.

Section 143(3)Section 263Section 54

setting aside the assessment order passed by the National e- Assessment Centre, Delhi ('AO') under section 143(3) of the Act as being erroneous and prejudicial to the interest of the revenue. The order passed under section 263 of the Act is bad in law and liable to be quashed ... allowed the deduction claimed without conducting necessary inquiries and verification. 2.5 In view of these facts, the assessment order was considered to be erroneous and prejudicial to the interests of revenue in terms of Sec. 263. It was therefore, proposed to pass an order u/s. 263 in this case

Smt. Bridget Anthony(Legal Heir of Late Mr. Elevathingal Joseph Anthony), Bangalore vs. Income-Tax Officer, Ward-4(2)(1), Bangalore

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 509/BANG/2024[2015-16]Status: DisposedITAT Bangalore05 Aug 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Sri Sandeep Chalapathy, A.RFor Respondent: Shri V. Parithivel, D.R
Section 143(2)Section 250Section 69

holding that there is a failure of the assessing officer to verify other aspects by rendering the assessment order as erroneous and prejudicial to the interests of the revenue. (Placed at Page No. 41 to 48 of assessee’s paper book). 5.7 The ld. A.R. relied on the decision ... holding that there is a failure of the assessing officer to verify other aspects by rendering the assessment order as erroneous and prejudicial to the interests of the revenue. 5.11 He submitted that the learned assessing officer has not converted the limited scrutiny to complete scrutiny for completing the assessment

Mahesh Reddy, Bangalore vs. Principal Commissioner of Income Tax, Bengaluru-2, Bengaluru

ITA 1379/BANG/2024[2017-18]Status: DisposedITAT Bangalore05 Aug 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Sri K.R. Pradeep, A.R. & Ms. Girija G.P., A.RFor Respondent: Sri Kiran D., D.R
Section 143(3)Section 263Section 54

setting aside the assessment order passed by the National e- Assessment Centre, Delhi ('AO') under section 143(3) of the Act as being erroneous and prejudicial to the interest of the revenue. The order passed under section 263 of the Act is bad in law and liable to be quashed ... allowed the deduction claimed without conducting necessary inquiries and verification. 2.5 In view of these facts, the assessment order was considered to be erroneous and prejudicial to the interests of revenue in terms of Sec. 263. It was therefore, proposed to pass an order u/s. 263 in this case

Inter Gold (India) Private Limited, Mumbai vs. PCIT-2, Mumbai

In the result, appeal of the assessee is allowed

ITA 4400/MUM/2023[2018-19]Status: DisposedITAT Mumbai05 Aug 2024AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 115JSection 142(1)Section 143(3)Section 263Section 80G

u/s.80G, the same is allowable, because both operate seperately. Thus, taking a contrary opinion does not mean that order of the ld. AO erroneous and prejudicial to the interest of the Revenue. 12. Claiming a deduction from computation of business income as provided from sections 28 to 44DB is different ... satisfied. Thus, allowing the claim of deduction u/s.80G by the ld. AO cannot be held to be unsustainable in law or amounts to erroneous and prejudicial to the interest of the Revenue. Thus order of the Ld. PCIT is reversed on this point. 13. In so far as bank charges

Shail Gas Pvt Ltd, Ghazaibad vs. Pr.CIT -7, New Delhi

In the result, the appeal of the assessee is allowed

ITA 630/DEL/2021[2015-16]Status: DisposedITAT Delhi05 Aug 2024AY 2015-16

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Akhilesh Kumar, Adv. &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 14ASection 263Section 56(2)(via)

These were, as rightly noted by the IT A T, unconnected issues and the assessment order could not have been held to be "erroneous and prejudicial to the interest of Revenue" when the AO could not have travelled beyond the issues forming subject matter of the 'limited scrutiny