2023 (9) TMI 695 - GUJARAT HIGH COURT

Revision u/s 263 - assessee took benefit of the Direct Tax Vivad se Vishwas Scheme - HELD THAT:- It was not open for the authorities to initiate proceedings under Section 263 of the Act, especially when they were clearly so barred. We are also conscious of the fact that even if the appeal memo which is placed on record is seen, the matter in issue before the CIT (Appeals) which was sought to be brought to rest by opting for the benefit of the Scheme was in context of the same issue which the Revenue sought to invoke by issuing notice u/s 263 of the Act.