Returns of income was not subjected to scrutiny assessment. There was search proceedings. Return income is accepted in search proceedings. Commissioner revised the assessment order on the basis of finding that stamp duty value of property is higher than sale consideration. On appeal the Tribunal held that no new discovery of fact in course of search, no incriminating material was found during search. Revision order is quashed. (AY. 2014-15)
Arati Ray v.Dy. CIT (2024)115 ITR 1 (Kol)(Trib) Mallika Roy v.Dy. CIT (2024)115 ITR 1 (Kol)(Trib) Samit Roy v.Dy. CIT (2024)115 ITR 1 (Kol)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital gains-Search and seizure-Stamp duty valuation-No new discovery of fact-Order of revision is quashed. [S. 45,48, 50C, 153A]
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