Income Tax Act with effect from 01.04.2022 which specifies any audit
objection and not only the C&AG audit objection thereby including the
internal ... internal audit memo dated 06.02.2018 issued by ACIT
(OSD) Audit - 1(2), Mumbai and thus the same cannot be considered to be
an objection raised
objection raised by the audit party which is not in
accordance with law. It was submitted that mere audit objection and
merely because a different ... That the learned Pr. CIT has failed to appreciate that audit
objection could not be made a valid basis to invoke section
passed. The assessee
contended that on the basis of certain audit objection, a query was made in respect
of amounts reflecting in Form ... under
section 148 of the Act, simply because there was an audit objection against the
original assessment. It was submitted that since the proceedings
Income Tax Act with effect from 01.04.2022 which specifies any audit
objection and not only the C&AG audit objection thereby including the
internal ... internal audit memo dated 06.02.2018 issued by ACIT
(OSD) Audit - 1(2), Mumbai and thus the same cannot be considered to be
an objection raised
passed. The assessee
contended that on the basis of certain audit objection, a query was made in respect
of amounts reflecting in Form ... under
section 148 of the Act, simply because there was an audit objection against the
original assessment. It was submitted that since the proceedings
careful verification of the ledger accounts based on which
the audit objection is raised, it is found that none of the payments have exceeded ... director of
audit, the Assessing Officer had opposed the reopening. In spite of the same, even
after disagreeing with the audit objection, as a second
assessment
proceedings and also before the Revenue Audit Party which is evident
from the reply to audit objection as reproduced supra. Reliance in this
regard ... also uses the
same language used by the Revenue Audit Party in its Audit Objection.
Hence revision proceedings could not be invoked
paper book and it was submitted that the
audit memo relates to certain minor Revenue audit objection relating to non
deduction of TDS on commission ... getting the account audited under
section 44AB of the Act. We therefore find that the revenue audit objection
could be the initial trigger where
found that the case was reopened on the basis of audit
objection. In the assessment record, it is further found that there is a letter ... audit officer on 12.06.2014 disposing/settling
these objections. However, the AO again reopened the case of
the assessee on the basis of same audit objection
basis that re-opening was done
based on the audit objection. The CIT(A) has failed
to note that the Hon'ble Supreme Court ... erred in initiating the
re-assessment proceedings based on audit objection. In support of
the grounds raised, the assessee filed detailed submissions before
