Bench: Shri Sonjoy Sarma, Hon’Ble & Shri Girish Agrawal, Hon’Bleassessment Year: 2013-14 M/S. Aditya Futuristic Trading Cit-1, Patna Pvt. Ltd. C/O. Nirmal & Associates, Chartered Accountants, Nepali Vs. Kothi, Opp. Gasoline Petrol Pump. Boring Road, Patna – 800001. [Pan: Aaeca 9085 E] (Appellant) (Respondent) Present For: Assessee By : Shri Nishant Maitin, Ca Revenue By : Smt. Rinku Singh, Cit/Dr Date Of Hearing : 13.12.2022 Date Of Pronouncement : 22.12.2022 O R D E R Per Sonjoy Sarma, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of Ld. Pcit-1, Patna Dated 23.03.2018 U/S 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). The Assessee Has Taken The Following Grounds Of Appeal: “I. For That The Grounds Hereto Are Without Prejudice To Each Other. Ii. For That The Order Passed By Ld. Commissioner Of Income-Tax-1, Patna Is Bad Both In Law & On Facts. Iii. For That The Order Passed By Ld. Commissioner Of Income-Tax-1, Patna Is Based On Presumption, Surmise & Conjectures. Iv. For That The Ld. Commissioner Of Income-Tax-1, Patna Passed The Order Ignoring The Fact That All The Points Which Were Raised In The Notice Had Duly Been Examined By The Ld. Ao.

depreciation chart and to determine the issue of deductibility of the same against the Gross Revenue Receipt (GRP). The failure of the Assessing Officer to conduct necessary enquiry and investigation to determine the nature of loss on capital assets 4 M/s. Aditya Futuristic Trading Pvt. Ltd. A.Y. 2013-14 as well as the amount being deductible against Gross Receipt