Mahesh Reddy, Bangalore vs. Principal Commissioner of Income Tax, Bengaluru-2, Bengaluru
ITA 1379/BANG/2024[2017-18]Status: DisposedITAT Bangalore05 Aug 2024AY 2017-18
Bench: Shri Chandra Poojari & Shri Soundararajan K.
For Appellant: Sri K.R. Pradeep, A.R. & Ms. Girija G.P., A.RFor Respondent: Sri Kiran D., D.R
Section 143(3)Section 263Section 54
…this procedure is contrary to the decision of the Hon'ble Supreme Court in CIT, Bangalore v. Shree Manjunathesware Packing Products (1998) 1 SCC 598, wherein held as under: ''28. The judgment of CIT, Bangalore v. Shree Manjunatheaware Packing Products (1998) 1 SCC 598, dealt with the issue as to what would be the scope of the expression “record” found in Section 263 of the Act, i.e., whether it would include the material placed before the AO or the material that was filed before the authority exercising the revisionary power as well. The Commissioner in this case had exercised the revisionary power after taking…