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2023 (8) TMI 160 - DELHI HIGH COURTRevision u/s 263 against company as dissolved - petitioner as the agent of Monet [company as dissolved] - share transfer transaction, prima-facie appears to be a tax avoidance arrangement to avoid paying taxes in India - Who may be regarded as agent u/s 163? - As decided by ITAT order passed u/s 163 by the CIT deserves to be quashed and treated as nonest. CIT assumed jurisdiction u/s 263 of the Act on the basis of order passed u/s 163 of the Act. HELD THAT:- Since the very basis [order u/s 163 of the Act] has been removed, the super structure i.e. order u/s 263 of the Act must fall.” Having regard to the operative directions issued by the Tribunal, according to us, these writ petitions would not lie, as obviously, the court cannot quash something, which has already been quashed by the Tribunal.
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