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2023 (10) TMI 615 - ITAT DELHIRevision u/s 263 - grant additional TDS credit - Tribunal allowing the appeal of the assessee [2022 (7) TMI 1406 - ITAT DLEHI] - HELD THAT:- As first revision order passed u/s 263 of the Act by the Ld. PCIT dated 23/03/2020, the said issue was already decided by the CIT(A) vide order dated 08/05/2019. Hence, on the date of initiation of section 263 proceedings on 02/08/2019, CIT(A) had already disposed of the appeal on 08/05/2019 by adjudicating the issue on merits. Hence, this issue of grant additional TDS credit was already considered and decided by the Ld. CIT(A) by his order dated 08.05.2019. Hence, for adjudication of very same issue, the Ld. PCIT cannot invoke revision proceedings u/s 263 of the Act in view of the provisions of Explanation-1(c) to section 263(1) of the Act. Assessee appeal allowed.
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