Doctrine of merger - Validity of Revision u/s 263 when existing ...

Merger Doctrine Invalidates Revision u/s 263 During Pending Appeal on Income Tax Assessment Order.

January 12, 2024

Case Laws Income Tax AT

Doctrine of merger - Validity of Revision u/s 263 when existing pending appeal against order passed u/s 153C r.w.s. 144 - when larger issue was pending before CIT(A), the revisionary authority could not exercise jurisdiction u/s 263. thus we would hold that the impugned revision u/s 263 was bad-in-law - AT

View Source

← Previous Next →

Doctrine of merger - Validity of Revision u/s 263 when existing ...

Merger Doctrine Invalidates Revision u/s 263 During Pending Appeal on Income Tax Assessment Order.

January 12, 2024

Case Laws Income Tax AT

You may also like:

Revision u/s 263 - Doctrine of merger - the subject-matter in question “Disallowance under section 14A r.w.r.8D” ‘ has been considered and decided by the Commissioner of...

Revision u/s 263 - Assessment u/s 153C - revision of invalid assessment - the present proceedings being collateral proceedings and if the assessment order is inherently...

Revision u/s 263 by CIT - Second Pr. CIT find the order of Second AO erroneous for lack of enquiry - Scope of doctrine of merger - The Ld. Pr. CIT has made a bald...

Revision u/s 263 - Doctrine of merger - When the issue flagged by Ld. PCIT has never been ascertained/examined to compute the correct book profit qua the transfer of...

Revision u/s 263 - successor PCIT / CIT did not agree with his predecessor - second revision order - assessment has been set aside or de novo assessment - sending of the...

The Rajasthan High Court examined the validity of revision proceedings u/s 263 concerning the period of limitation. The issue was whether the period of limitation for...

Revision u/s 263 or appeal-able order before CIT(A) u/s 246A - Subject matter of revision was limited - Doctrine of merger - CIT(A) and ITAT rejected the appeal of...

Revision u.s 263 - assessment order passed pursuant to the revisionary order has resulted in reduction of tax liability - not prejudicial to the interest of the Revenue...

Refund claim - Period of limitation - Doctrine of merger - importer having registered a ‘Protest’ - The Tribunal held that, "the doctrine of merger" implies that the...

Revision u/s 263 - period of limitation for passing order - Only in a case where the issues before the Commissioner at the time of exercising powers u/s 263 relate to...

Revision u/s 263 - Period of limitation - To be commenced from original assessment order or re-assessment order u/s 147 - In the case on hand, the jurisdiction under...

Revision u/s 263 - CIT setting aside the second reassessment order - time limit to take action u/s 263 - the necessity for the Commissioner to have substantial grounds...

Validity of revision u/s 263 against order u/s 143(3) r/w section 153A - The assessment order was passed with prior approval under Section 153D - The High court examined...

Validity of revision u/s 263 - subsequent revision orders - first order set aside by PCIT - ITAT quashing revisionary proceedings - adoption of accrual basis of...

Revision u/s 263 - Validity of order of ITAT, cancelling the order of assessment u/s 115 WE(3) and directing the assessing officer to make an order de novo only for the...

Quick Updates: