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TMI Blog2024 (3) TMI 32X X X X Extracts X X X X X X X X Extracts X X X X ..... een pleased to observe opting the VSV Scheme and finalizing thereof is nothing but the closure of disputes in respect of tax arrears which cannot be subsequently reopened by issuing notice u/s 263 of the Act for revising the assessment order. Hence, we hold that the order passed u/s 263 on the assessment order which has already been settled under VSVS is invalid and the same is liable to be dis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng incorrect facts and findings and in violation of principles of natural justice. 2. That Ld. Pr.CIT has erred both in law and on facts in setting aside the impugned assessment order dated 22-12-2019 and has further erred in directing Ld. AO to examine the issues afresh and that too by recording incorrect facts and findings, without providing adequate opportunity of hearing and by disregarding ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... action of ld. Pr.CIT in passing the impugned order u/s 263 is bad in law and against the facts and circumstances of the case and in violation of rudimentary principles of contemporary jurisprudence. 3. At the outset, ld. Counsel of the assessee stated that assessment order on which ld. Pr.CIT has exercised jurisdiction under section 263 of the Income-tax Act, 1961 (for short the Act ) has al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lT (supra). We find that the Hon'ble Court has been pleased to observe opting the VSV Scheme and finalizing thereof is nothing but the closure of disputes in respect of tax arrears which cannot be subsequently reopened by issuing notice under Section 263 of the Act for revising the assessment order. Needless to mention that the view is squarely applicable in favour of the assessee before us. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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