M/S SURJEET AUTO AGENCY ,BHOPAL vs. PR CIT-2, BHOPAL

Bench: Shri Manish Borad & Mis Madhumita Royassessment Year:2015-16 M/S Surjeet Auto Agency, Pr. Cit-2, 4-5, Lajpat Nagar, Raisen Bhopal बनाम/ Road, Apsara Cinema, Vs. Bhopal (Appellant) (Respondent ) P.A. No. Aatfs 4110J Appellant By S/Shri Sumit Nema, Sr. Adv. & Gagan Tiwari, Piush Parasar Advs. Revenue By Shri S.B. Prasad, Cit-Dr Date Of Hearing: 13.04.2021 Date Of Pronouncement: 25.05.2021 आदेश / O R D E R Per Manish Borad, A.M: By Way Of This Appeal, The Appellant Has Challenged The Assumption Of Jurisdiction U/S 263 Of The Income Tax Act 1961( Hereinafter Referred To As ‘The Act’ For Short) By Ld. Pr. Cit-2 Bhopal Vide Order Dated 04.02.2020.The Assessee Has Raised Following Grounds Of Appeal:-

391/- and other expenses at Rs.3,00,000/-, thereby assessing income at Rs.62,50,011/-. 3. Subsequently, Ld. Pr. CIT, Bhopal invoked the provisions of section 263 of the Act and issued following show cause notice to the assessee(relevant extract is reproduced below): “Please refer to the order u/s 143(3) of the IT Act, 1961 dated 26.04.2017 passed

DEPUTY COMMISSIONER OF INCOME TAX -5(1), INDORE vs. M/S SUNDERDEEP CONSTRUCTIONS PVT. LTD. , INDORE

In the result both the appeals of the revenue vide ITA No

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

property was transferred during F.Y 2009-10. 2.Whether on the facts and in the circumstances of the case the Ld. CIT (A) was justified in holding that the AO has made addition by disallowing development expenses of Rs.2,93,76,558/- on presumption basis whereas the fact is that the claim made by the assessee for development expenses has been

DEPUTY COMMISSIONER OF INCOME TAX -5(1), INDORE vs. M/S SUNDERDEEP CONSTRUCTIONS PVT. LTD. , INDORE

In the result both the appeals of the revenue vide ITA No

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

property was transferred during F.Y 2009-10. 2.Whether on the facts and in the circumstances of the case the Ld. CIT (A) was justified in holding that the AO has made addition by disallowing development expenses of Rs.2,93,76,558/- on presumption basis whereas the fact is that the claim made by the assessee for development expenses has been