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The assessee submitted reply before the learned Principal CIT stating that the trading activities took place during the period in consideration, the losses claimed in Bardana account, Husk account, Phuck account, Rice account were due to poor quality of the items, depreciation was rightly claimed on building and machinery as trading was done during the relevant period. Cash Balance of Rs. 65,65,625 was the opening cash and sales/business receipts during the year, cash deposits were out of sale proceeds during the year. A copy of account of commodity profit has also been furnished. It has further been stated that most of the assets do not fall under the ambit of WT Act and that all assets were old and not acquired during the year under consideration.However, the Principal CIT rejected the submissions of the assessee and held that the order passed by the AO is erroneous and prejudicial to the interest of the Revenue.Aggrieved by the order of the learned Principal CIT the assessee is in appeal before Tribunal.

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Sec. 263 of Income-tax Act, 1961— Revision—Where the AO has examined and enquired about assessee's accounts and details filed by the assessee and applied his mind to the facts of the case and after being satisfied with all the details and documents, the AO had framed the assessment merely for reason that CIT was not satisfied with manner of verification and investigation carried out by the AO, assessment order could not be held as to be erroneous, therefore, it is abundantly clear that AO has initiated a limited scrutiny and asked the assessee to file the specific details and documents and assessee submitted the specific and required documents and details as mentioned in the reply of the assessee and after doing detailed scrutiny of the documents/evidences, the AO framed assessment order, therefore, order passed by AO is not erroneous. - MANDEEP SINGH DHILLON V/s PR. CIT - [2020] 207 TTJ 009 (UO)(ITAT-AMRITSAR)

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