In the result, appeal of the assessee is dismissed
Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.811/Pun/2025 Assessment Year : 2018-19
same 11 Universal Reality because without doing so proceedings u/s 264 of the Act could not be initiated in terms of provision of Section 264(4)(b) of the Act. Therefore, by doing so the ld. CIT(A) has acted well within the powers provided