DCIT 5 3 1 , MUMBAI vs. ALTR INTERNATIONAL PVT LTD, MUMBAI

PER OM PRAKASH KANT, AM

The captioned appeals have been preferred by the Revenue against two separate order, dated 22.01.2025 and 28.11.2024
passed by the National Faceless Assessment Centre, Delhi [ in short the ld CIT(A)] for assessment years 2008-09 and 2009-10
respectively. The facts of both the appeals being identical, both parties agreed to tak apply result of said mutandis.
2. Briefly stated, fa
Principal. Commissio records and after p assessee, cancelled t of revision order da
Officer to pass a fresh order has been pass the Act. Subsequently the Act before the T
21.10.2022 quashed
PCIT. As the order u/
consequent assessm relief to the assessee
“7.4.1 The cu dated 30.11.2
order passed
ITAT, therefor u/s 143(3) r.w
3. We have heard the relevant materia order of the Ld. CIT(A passed consequent t
ALTR
ITA Nos.

ke the appeal for AY 208-09 as d appeal to appeal for AY 2
acts of the case for AY 2008-09
oner of Income-tax (PCIT), called providing opportunity of being the reassessment order passed ated 23/03/2018 and directed h assessment order. The impug ed in consequent to the said o ly, the assessee challenged the o
Tribunal and the Tribunal vide d the order passed u/s 263 of /s 263 stands quashed, the Ld.
ment proceedings as infructuou observing as under:
urrent appeal arises from the assessmen
2018 passed u/s 143(3) r.w.s 263. Sin d u/s 263 has been quashed by the H re, consequentially the impugned order ws 263 does not survive.”
rival submissions of the parti ls on record. The present appe
A) which are arising from the as to the order u/s 263 of the Act
R International Pvt. Ltd
2
450 & 451/MUM/2025
s lead case and 009-10 mutatis are that the Ld.
d for assessment g heard to the by him by way d the Assessing gned assessment rder u/s 263 of order u/s 263 of its order dated the Act by the . CIT(A) held the us and allowed nt order nce, the Hon’ble passed ies and perused eals against the ssessment order t passed by the Ld. PCIT. Since the o itself has been quas survive. Accordingly,
Ld. CIT(A) on the is grounds raised by dismissed.
3.1 The facts of th grounds raised by th accordingly dismissed
4. In the result, bo
Order pronoun (KAVITHA RA
JUDICIAL M
Mumbai;
Dated: 07/03/2025
Rahul Sharma, Sr. P.S.

Copy of the Order forward
1. The Appellant
2. The Respondent.
3. CIT
4. DR, ITAT, Mumbai
5. Guard file.

////

ALTR
ITA Nos.

order passed by the Ld. PCIT u/
hed, the consequent assessmen we do not find any infirmity in ssue in dispute and uphold h the Revenue in the appeal he case for AY 2009-10 being he Revenue in the appeal for A d.
oth the appeals of the Revenue a ced in the open Court on 07/0
/- AJAGOPAL)
(OM PRAK
MEMBER
ACCOUNTA ded to :

BY ORDER

(Assistant Re

ITAT, Mu
R International Pvt. Ltd
3
450 & 451/MUM/2025
s 263 of the Act nt order cannot the order of the his finding. The are accordingly identical , The AY 2009-10 are are dismissed.
03/2025. d/-
KASH KANT)
ANT MEMBER
R, gistrar) umbai