PCIT barred from revising assessment when TDS issue already under appeal.

The Principal Commissioner of Income Tax (PCIT) was deemed to lack jurisdiction to revise an assessment order under section 263 concerning unpaid TDS when the issue was already under appeal with the Commissioner of Income Tax (Appeals) [CIT(A)]. According to Explanation 1(c) to section 263, the PCIT cannot initiate revision proceedings if an appeal is pending before the CIT(A), whose powers are equivalent to those of the Assessing Officer. This statutory restriction was upheld in previous cases, and the decision favored the assessee. .....

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