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2022 (9) TMI 1187 - AT - Income TaxRevision u/s 263 by CIT - application under Vivad Se Vishwas 2020 made - addition in respect of deemed rent U/s 22 r.w.s. 23 of the Act has filed an appeal with the CIT(A) and during pendency of the appeal - HELD THAT:- We find the assessment order under Section 143(3) of the Act was passed on 24.11.2019. On appeal, the CIT(A) considering the facts of VSVS 2020 by the assessee has passed the order U/sec 250 of the Act on 26-05-2021. Whereas, the Pr.CIT on the same facts, were the A.O. has applied the mind and made an addition and passed order, now the Pr.CIT has issued notice u/sec 263 of the Act on 03-03-2022 and passed revision order on 15-03-2022. We are of the opinion that the Pr.CIT has invoked provisions of section 263 of the Act after conclusion of proceedings were the assessee has opted VSVS 2020 and received Form.no.5 after payment of full/final disputed taxes on 1.05.2021. Hence the revision order passed U/sec 263 of the Act is abated. See GOPALAKRISHNAN RAJKUMAR, GOPALAKRISHNAN RAVIM [2022 (5) TMI 1388 - MADRAS HIGH COURT] - Appeal of assessee allowed.
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