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Facts
The assessee's appeal for AY 2017-18 arose against an order passed under section 143(3) r.w.s. 263 of the Income Tax Act. The original revision directions were passed by the PCIT under section 263.
Held
The Tribunal noted that a coordinate bench had already reversed the PCIT's section 263 revision directions. Consequently, the Tribunal held that the impugned assessment order and the lower appellate order had no basis and were therefore quashed.
Key Issues
Validity of assessment order and lower appellate order in light of a prior coordinate bench decision reversing the section 263 revision directions.
Sections Cited
143(3), 263
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DEHRADUN BENCH “DB”, DEHRADUN
Before: Sh. Satbeer Singh Godara & Sh. Manish Agarwal
ORDER
Per Satbeer Singh Godara, Judicial Member:
This assessee’s appeal for Assessment Year 2017-18, arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1078509132(1) dated 15.07.2025, in proceedings u/s 143(3) r.w.s. 263 of the Income Tax Act, 1961.
Heard both the parties at length. Case file perused.
It emerges at the outset that we hardly need to deal with the relevant factual matrix at length so far as the assessee’s instant appeal involving section 143(3) r.w.s. 263 proceedings; is concerned. This is for the precise reason that the learned co- ordinate bench’s order dated 18.02.2026 has reversed the PCIT’s section 263 revision directions dated 27.03.2022 itself in ITA No. 31/DDN/2022.
That being the case, we are of the considered view that both the impugned assessment order dated 21.03.2023 as well as the lower appeal one dated 15.07.2025 in issue have no legs to stand in the foregoing terms. Quashed accordingly.
All other remaining pleadings between the parties stand rendered academic.