JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1, COIMBATORE, COIMBATORE vs. PRABHUKAANT KANIMOZHI, ERODE

This appeal filed by the Revenue is directed against the order dated 13.12.2024 passed by the ld. Commissioner of Income Tax (Appeals) – 20, Chennai for the assessment year 2017-18.

The ld. AR Shri S. Sridhar, Advocate submits that the assessment was completed under section 143(3) r.w.s. 263 of the Income Tax Act, 1961 [“Act” in short] dated 30.09.2022 and the & C.O. No. 36/Chny/24 additions were made in pursuance to the revision order passed under section 263 of the Act dated 23.03.2022. He further submits that against the revision order passed under section 263 of the Act, the assessee preferred an appeal before the ITAT, and the Tribunal vide its order dated 21.04.2023 in quashed the revision order passed by the ld. PCIT. He argued that the assessment order passed in pursuance to the revision order under section 263 of the Act has no legal sanctity and the ld. CIT(A) has rightly dismissed the appeal filed against the assessment order under section 143(3) r.w.s. 263 of the Act as infructuous. Thus, the ld. AR prayed that the appeal preferred by the Appellant-Revenue against the impugned order should be dismissed as infructuous.

The ld. DR Ms. D. Babitha, JCIT reported no objection. In view of the above facts and circumstances, the appeal preferred by the Appellant – Revenue is dismissed as infructuous.

In the result, both the appeal filed by the Revenue and the Cross Objections filed by the assessee are dismissed. Order pronounced in the open Court on 09th July, 2025 at Chennai.