GURBAKSHISH SINGH BATRA,DELHI vs. ACIT,CIRCLE-52(1), DELHI

This assessee’s appeal for assessment year 2016-17, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2024-25/1076512196(1), dated 28.05.2025 involving proceedings under section 144 r.w.s. 263 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

It transpires during the course of hearing that there is hardly any need to delve with the relevant factual matrix at length in the assessee’s appeal. This is for the precise reason that the assessing authority has framed the impugned assessment dated 30th March, 2022 in compliance to the learned PCIT’s section 263 revision directions dated 22nd March, 2021 terming the former assessment completed on 28.11.2018 as an erroneous one causing prejudice to the interest of the Revenue.

It is in this factual backdrop that the assessee has invited our attention to the learned coordinate bench’s order in his appeal decided on 31st March, 2022 against the department thereby annulling the PCIT’s foregoing revision directions itself. We thus conclude that the impugned consequential assessment has no legs to stand once the learned PCIT’s revision direction already quashed. We thus conclude that the impugned latter assessment dated 30.03.2022 must also follow the suit in very terms. Ordered accordingly. All other pleadings on merits between the parties stand rendered academic.

This assessee’s appeal is allowed.