Aryadeep Complex (P)Ltd. v. PCIT (2022) 219 TTJ 735 /218 DTR 25 (Raipur)(Trib)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limited scrutiny-PCIT cannot travel beyond the Limited scrutiny Investment-Investment reflected in balance sheet-Furnished basic details-Direction was modified to consider the investment made in the course of the set aside proceedings. [S. 143(3)]

Held that the in the revision proceedings the PCIT cannot travel beyond the Limited scrutiny. Assessee having merely furnished the details of its substantial statements in unquoted equity shares in response to the queries raised by the Assessing Officer  such furnishing of bare basic details cannot be brought within the realm of making of enquiries or carrying out verification and therefore, the order passed by the AO under s. 143(3), is erroneous insofar it is prejudicial to the interest of the Revenue on the said count ie., failure on the part of the AO in carrying out verifications as regards the substantial investments. Accordingly the direction of the PCIT was modified to consider the investment made in the course of the set aside proceedings.  (AY. 2015-16)