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2020 (1) TMI 335 - HC - Income TaxRevision u/s 263 - Whether the order u/s. 263 passed by the Principal Commissioner of Income Tax who has validly assumed jurisdiction within two years from the end of the financial year in which the impugned order under reference was passed? - HELD THAT:- It appears from the finding recorded by the appellate tribunal that as the reassessment proceedings came to be quashed and the same has been accepted by the department, according to the appellate tribunal, there is no scope now for the Commissioner to exercise any power under Section 263 of the Act, 1961. Having heard the learned senior counsel Mr. Bhatt appearing for the revenue and having gone through the materials on record, we are of the view that there is no substantial question of law involved in this appeal. Although Mr. Bhatt tried to persuade us to take the view that the two issues on which the power is required to be exercised under Section 263 of the Act. As the reassessment proceedings came to be quashed and the same has been accepted, no useful purpose would now be served to permit the Commissioner to exercise power under Section263 - Decided against revenue.
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