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2023 (8) TMI 388 - HC - Income TaxRevision u/s 263 by CIT - scope of revision proceedings - ITAT came to a finding that the Principal CIT could not have invoked jurisdiction u/s 263 as AO has taken a possible view in the matter and there is nothing to indicate that the AO has applied the provisions on an incorrect way - HELD THAT:- Since the view taken by the Assessing Officer is a possible view, the Principal CIT has assumed jurisdiction u/s 263 of the Act without properly complying with the mandate of Section 263 - ITAT held that the Principal CIT has failed to show that the Assessment Order was erroneous, causing prejudice to the Revenue. This finding of the ITAT that the Principal CIT could not have exercised its jurisdiction under Section 263 of the Act has not been even challenged. Since that has not been challenged, we do not think it permissible to go into the merits of the case - No substantial questions of law arises.
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