TMI Blog2014 (8) TMI 647X X X X Extracts X X X X X X X X Extracts X X X X ..... he Act, the assessee preferred an appeal - in view of Section 264(4)(c) of the Act, the Commissioner has no power to revise any order u/s 264 of the Act since the order was subject to an appeal before the Appellate Tribunal – there was no error in the order passed by the CIT u/s 264 of the Act – Decided against - Writ Tax No. - 175 of 2008 - - - Dated:- 19-8-2014 - Hon'ble Tarun Agarwala A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Act. The petitioner submitted a reply and thereafter the assessing officer passed an order under Section 201(1) of the Act treating the petitioner as an assessee in default and directed the petitioner to pay an amount of ₹ 23,26,768/- towards T.D.S. along with interest. The petitioner, did not prefer any appeal, but preferred an application under Section 154 of the Act for rectifi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s filed the present writ petition. We have heard Sri Shakeel Ahmad, the learned counsel for the petitioner and the learned counsel for the Income Tax department. Section 264 of the Act provides that the Commissioner on his own motion or on an application by the assessee may apply for revision by calling for the record of any proceeding under this Act, in the case of any order other than an o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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