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“revision u/s 263”

Rectification & RevisionSection 263Section 263521 judgments

The decision most relied on for revision u/s 263 is CIT v. Amitabh Bachchan (384 ITR 200), cited in 264 judgments on BharatTax.

Leading authorities on revision u/s 263

CIT v. Amitabh Bachchan
384 ITR 200 · 2016 · Supreme Court
264
citing judgments

The Commissioner's revisional power under Section 263 of the Income Tax Act is not limited to the points specified in the show-cause notice, nor is the exercise of this power contingent upon issuing a show-cause notice.

Grasim Industries Ltd. v. CIT
321 ITR 92 · 2010 · High Court
194
citing judgments

This case clarifies the scope of the Commissioner's revisional powers under Section 263 of the Income-tax Act, holding that an assessment order can only be revised if it is both erroneous and prejudicial to the interests of the revenue, echoing the principles laid down in Malabar Industrial.

CIT v. Nirma Chemical Works Ltd.
309 ITR 67 · 2009 · High Court
149
citing judgments

An assessment order is not erroneous or prejudicial under Section 263 merely because it is silent on a claim or lacks explicit reasons for its acceptance. Revision under Section 263 is impermissible if the Assessing Officer has taken a plausible view, even if the PCIT holds a different opinion.

Babulal C. Borana v. ITO
282 ITR 251 · 2006 · High Court
138
citing judgments

An assessment order becomes erroneous and prejudicial to the revenue, justifying revision under Section 263, if the Assessing Officer fails to conduct proper inquiries or apply his mind to relevant issues, such as the genuineness of purchases when corresponding sales are accepted, often leading to a remand for fresh adjudication.

CIT v. Jawahar Bhattacharjee
341 ITR 434 · 2012 · High Court
99
citing judgments

An assessment order is erroneous for the purpose of Section 263 if the Assessing Officer fails to apply mind to relevant material, proceeds on an incorrect assumption of facts, or makes an incorrect application of law.

CIT v. Vodafone Essar South Ltd.
212 Taxmann 184 · 2013 · High Court
86
citing judgments

When an Assessing Officer conducts an inquiry and considers the assessee's disclosures, the Commissioner cannot invoke Section 263 to revise the assessment on grounds of inadequate inquiry or a mere difference of opinion. The absence of a detailed discussion on an issue in the assessment order does not automatically mean the Assessing Officer failed to apply his mind.

Principal Commissioner of Income-tax, Surat-2 v. Shreeji Prints (P.) Ltd.
130 Taxmann.com 294 · 2021 · Supreme Court
78
citing judgments

A plausible view taken by the Assessing Officer, after due enquiry and verification, does not render an assessment order erroneous and prejudicial to the interest of revenue for the purpose of revision under Section 263, thereby limiting the scope of revisional powers.

Income-Tax v. Gokuldas Exports
333 ITR 214 · 2011 · High Court
42
citing judgments

An assessment order is not considered erroneous and prejudicial to the interests of the Revenue for invoking Section 263 if the Assessing Officer has adopted one of two possible views, even if the Commissioner of Income-tax disagrees with that view. The phrase 'prejudicial to the interests of the Revenue' must be read in conjunction with the expression 'erroneous'.

Judgments citing revision u/s 263

Anirudh Murthy Ranga, Mysuru vs. Principal Commissioner of Income Tax, (Central), Bengaluru

In the result, both the appeals of the assessees are dismissed

ITA 676/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Feb 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143Section 263Section 54FSection 57

explanation tendered, the deduction claimed was allowed and the income returned was accepted in the order of assessment passed u/s.143[3] dated 29/10/2018. REVISION u/s 263 8. The PCIT issued a notice u/s. 263 of the Act dated 12/03/2021 proposing to revise the assessment order passed u/s

Mr. Kishore Nandlal Chabria, Mumbai vs. The Pr. CIT-16, Mumbai

In the result, the appeal of the assessee is hereby allowed

ITA 1554/MUM/2020[2015-16]Status: DisposedITAT Mumbai10 Feb 2022AY 2015-16

Bench: Shri Shamim Yahya, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.1554/Mum/2020 (ननधधारण वर्ा / Assessment Years: 2015-16) बनधम/ Mr. Kishore Nandlal Pcit-16 Room No.437, 4Th Floor Chabria Vs. 51, 5Th Floor, Radheya Aayakar Bhavan, Building, 14Th Road, Khar Maharishi Karve Road, West, Mumbai-400052. Mumbai-400020. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aabpc5779R (अपीलाथी /Appellant) (प्रत्यथी / Respondent) .. Assessee By: Shri Sanjay Singh Revenue By: Shri Vinay Sinha (Dr) सुनवाई की तारीख / Date Of Hearing: 16/11/2021 घोषणा की तारीख /Date Of Pronouncement: 10/02/2022 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 07.07.2020 Passed By The Principal Commissioner Of Income Tax-16, Mumbai [Hereinafter Referred To As The “Pcit”] Relevant To The A.Y.2015-16 In Which The Principal Commissioner Of Income Tax-16 Has Invoked The Provisions U/S 263 Of The I.T. Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal: - 2. 1. On The Facts & In The Circumstances Of The Case, The Order Passed By The Learned Principal Commissioner Of Income Tax-16, Mumbai Under Section 263 Of The Income Tax Act. 1961 Is Void Ab Initio Being Had In Law Based On Assumptions & Wrong Facts & Without Jurisdiction. 2. On The Facts & In The Circumstances Of The Case, The Learned Principal Commissioner Of Income Tax-16, Mumbai Has Erred On Facts & In Law In Assuming Jurisdiction Under Section 263 Of The Income Tax Act, 1961 When

For Appellant: Shri Sanjay SinghFor Respondent: Shri Vinay Sinha (DR)
Section 143(2)Section 143(3)Section 263Section 263(1)

invalid and the same is quashed for both the assessment years.” 10. Therefore, we are of the view that the revision u/s 263 of the Act bad in law. Accordingly, we set aside the order passed by the PCIT u/s 263 of the Act. 11. In the result, the appeal

M/S Volvo India Pvt. Ltd., Hosakote vs. CIT, Bangalore

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 687/BANG/2015[2008-09]Status: DisposedITAT Bangalore27 Jan 2022AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2008-09

For Appellant: Shri Pavan Kumar, AdvocateFor Respondent: Shri Pradeep Kumar, Jt.CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 263Section 40

under the provisions of sec.263 of the Act. The only ground on which the ld.CIT(LTU) exercised the power of revision u/s 263 was that the claim of allowance of Rs.2,36,07,661/- under the provisions of sec. 40(a)(ia) was not examined by the AO during ... assuming jurisdiction under the provisions of sec.263 of the Act. The only ground on which the ld.CIT(LTU) exercised the power of revision u/s 263 was that the claim of allowance of Rs.2,36,07,661/- under the provisions of sec. 40(a)(ia) was not examined

M/S. Asaria Lalji Vador, Mumbai vs. Pr. CIT -7, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 559/MUM/2021[2016-17]Status: DisposedITAT Mumbai12 Jan 2022AY 2016-17

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Blem/S. Asaria Lalji Vador V. Office Of Pcit – 27 C-21, Mahavir Jyot Room No. 401, 4Th Floor Opp. Odeon Shopping Centre Tower No. 6 Ghatkopar (E), Mumbai -400077 Vashi Railway Station Building Complex Vashi, Navi Mumbai-400703 Pan: Aabpv0149A (Appellant) (Respondent) Assessee By : Shri Pradip Kapasi Department By : Ms. Shailja Rai

For Appellant: Shri Pradip KapasiFor Respondent: Ms. Shailja Rai
Section 143(2)Section 143(3)Section 263Section 54E

accordance with law. 5. Aggrieved with the above order, assessee is in appeal before us raising following grounds in its appeal: - “1. INVALID REVISION U/s. 263 a. The Ld. PCIT erred in law and facts of the case in initiating revisionary proceedings u/s. 263 and thereafter in passing an order ... 54EC was in any case allowable as per the provisions of law and the order passed by the A.O did not require any revision u/s 263. The said order was passed by the A.O. u/s 143(3) on 11.04.2018. iii. The appellant had made complete disclosure of the facts

Actia (India) Pvt. Ltd., New Delhi vs. Pr.CIT- 1, New Delhi

In the result, the appeal of the assessee is dismissed

ITA 7552/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Jan 2022AY 2012-13

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 7552/Del/2017 : Asstt. Year : 2012-13 Actia (India) Pvt. Ltd., Vs Pr. Cit-1, 1, Dakshineshwar, 10, Hailey Road, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aadca6944R Assessee By : None Revenue By : Sh. Mrinal Kumar Das, Sr. Dr Date Of Hearing: 05.01.2022 Date Of Pronouncement: 10.01.2022

For Appellant: NoneFor Respondent: Sh. Mrinal Kumar Das, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 234ASection 263Section 92CSection 92C(3)Section 92C(4)

Leisure Wear Exports Ltd. [2010] 46 DTR (Del) 97 Hon’ble Delhi High Court held that power of revision u/s 263 of the Act is not meant to be exercised for the purpose of directing the AO to hold another investigation, without describing as to how the order

Humuza Consultants, Mumbai vs. The Pr. CIT-19, Mumbai

In the result, appeal filed by the assessee is allowed and the stay application filed by the assessee is dismissed

ITA 726/MUM/2021[2015-16]Status: DisposedITAT Mumbai07 Jan 2022AY 2015-16

Bench: Shri Prashant Maharishi () & Shri Pavan Kumar Gadale () Humuza Consultants Vs The Principal Commissioner Of 6Th Floor, Wokhardt Towers Income-Tax-19, Mumbai Bandra Kurla Complex Room No. 228, 2Nd Floor, Bandra East Matru Mandir Mumbai-400 01 Tardeo Road, Pan : Aahfh9240E Mumbai-400 007 Appellant Respondent Appellant By Shri Jd Mistry & Hiten Chande Respondent By Shri K.K. Mishra (Cit,Dr) Date Of Hearing 07-12-2021 Date Of Pronouncement 07-01-2022 O R D E R Per Prashant Maharishi (Am):

Section 143Section 143(3)Section 263Section 56Section 68

following grounds of appeal On the facts and in circumstances of the case and in law, the learned principal CIT:- Revision U/S 263 of the Act 1) erred in holding that the assessment order dated 6 December 2017 passed u/s 143 (3) of the act by the learned assessing officer

ACIT, New Delhi vs. M/S Krishak Bharati Cooperative Ltd., New Delhi

In the result, the appeal of the assessee in ITA No

ITA 2973/DEL/2017[2011-12]Status: DisposedITAT Delhi29 Dec 2021AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

relief u/s 90 of the Income Tax Act 1961 under the Indo-Oman Double Taxation Treaty has been a subject matter of revision u/s 263 of the Income Tax Act 1961 by the Pr. Commissioner of Income Tax, Delhi-10 for the AY. 2010-11 and 2011-12. The Pr.CIT

ACIT, New Delhi vs. M/S Krishak Bharati Cooperative Ltd., New Delhi

In the result, the appeal of the assessee in ITA No

ITA 2972/DEL/2017[2010-11]Status: DisposedITAT Delhi29 Dec 2021AY 2010-11

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

relief u/s 90 of the Income Tax Act 1961 under the Indo-Oman Double Taxation Treaty has been a subject matter of revision u/s 263 of the Income Tax Act 1961 by the Pr. Commissioner of Income Tax, Delhi-10 for the AY. 2010-11 and 2011-12. The Pr.CIT

M/S. Krishak Bharti Cooperative Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 2342/DEL/2017[2011-12]Status: DisposedITAT Delhi29 Dec 2021AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

relief u/s 90 of the Income Tax Act 1961 under the Indo-Oman Double Taxation Treaty has been a subject matter of revision u/s 263 of the Income Tax Act 1961 by the Pr. Commissioner of Income Tax, Delhi-10 for the AY. 2010-11 and 2011-12. The Pr.CIT

M/S. Krishak Bharti Cooperative Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 2341/DEL/2017[2010-11]Status: DisposedITAT Delhi29 Dec 2021AY 2010-11

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

relief u/s 90 of the Income Tax Act 1961 under the Indo-Oman Double Taxation Treaty has been a subject matter of revision u/s 263 of the Income Tax Act 1961 by the Pr. Commissioner of Income Tax, Delhi-10 for the AY. 2010-11 and 2011-12. The Pr.CIT

M/S Robert Bosch Engineering and Business Solutions Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax Ltu, Bangalore

In the result, the appeal filed by the assessee is allowed

ITA 1637/BANG/2018[2011-12]Status: HeardITAT Bangalore22 Dec 2021AY 2011-12

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.Anand Sondur, CAFor Respondent: Smt.Priyadarshini Besaganni. JCIT-DR
Section 1Section 143(3)Section 154Section 263Section 3Section 36(1)(va)

Pvt.Ltd. 9. We have heard rival submissions and perused the material on record. On perusal of the assessment order, which was subjected to revision u/s 263 of the Act, we notice that there is no inquiry conducted by the A.O. in allowing the provision for bad and doubtful debts. Therefore

Pushp Steel and Mining Private Limited, Delhi vs. PCIT, Delhi-7

In the result, appeal of the assessee is allowed

ITA 811/DEL/2021[2015-16]Status: DisposedITAT Delhi22 Dec 2021AY 2015-16

Bench: Sh. Anil Chaturvedi & Sh. K. Narasimha Chary

Section 143(2)Section 143(3)Section 263Section 263(1)Section 56(2)(viia)

assessment and directing a fresh assessment.” 12. The reading of the above provision makes it very clear that the power of suo motu revision u/s 263(1) is in the nature of supervisory jurisdiction and the same can be exercised only if the circumstances specified therein exist. Two circumstances must ... exist to enable the Commissioner to exercise power of revision u/s 263, namely (i) the order is erroneous (ii) by virtue of being erroneous, prejudice has been caused to the interests of the Revenue. 13. Hon’ble Apex Court in the case of Malabar Industrial Co., Ltd., Vs CIT reported

Kapil Mehta, Delhi vs. PCIT(Central)-3, New Delhi

The appeal of the assessee stands dismissed

ITA 533/DEL/2021[2017-18]Status: FixedITAT Delhi11 Oct 2021AY 2017-18

Bench: The Assessing Officer

Section 131Section 132Section 143(3)Section 153ASection 263Section 263(1)

point out what more enquiries would the AO ought to have conducted. 11. The CIT has failed to appreciate that powers of revision u/s 263 cannot be exercised for redoing the investigation, rather the CIT ought to have done the investigation himself before restoring the matter ... been received u/s 153 D of the Act, the assessment order passed u/s 153A of the Act would not be subjected to revision u/s 263 of the Act. In this regard, the Ld. AR has placed reliance on a principle of judicial precedents and has prayed that the 263 order

Roop Kumar Bansal, Gurgaon vs. Pr, CIT (Central), Gurgaon

In the result, ITA.No.383/Del

ITA 386/DEL/2021[2017-18]Status: DisposedITAT Delhi31 May 2021AY 2017-18

Bench: Shri Bhavnesh Saini & Shri O.P.Kant

For Appellant: And Shri Lalit Mohan, C.AFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153B(1)(b)Section 263

386/Del./2021 Smt. Abha Bansal, Sh Pankaj Bansal, Sh Basant Bansal And Sh Roop Kumar Bansal, Gurgaon. Act cannot be subject matter of revision u/s 263 of the Act. (ii) That without prejudice assuming for the sake of an argument that approval u/s 153D of the Act is not valid ... therefore order of assessment u/s 153B(1)(b)/143(3) of the Act is a vitiated order which cannot be subject matter of revision u/s 263 of the Act. (iii) That the contention that order dated 18.12.2018 u/s 153B(1)(b)/143(3) of the Act is invalid

Shri Basant Bansal, Gurgaon vs. Pr, CIT (Central), Gurgaon

In the result, ITA.No.383/Del

ITA 385/DEL/2021[2017-18]Status: DisposedITAT Delhi31 May 2021AY 2017-18

Bench: Shri Bhavnesh Saini & Shri O.P.Kant

For Appellant: And Shri Lalit Mohan, C.AFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153B(1)(b)Section 263

386/Del./2021 Smt. Abha Bansal, Sh Pankaj Bansal, Sh Basant Bansal And Sh Roop Kumar Bansal, Gurgaon. Act cannot be subject matter of revision u/s 263 of the Act. (ii) That without prejudice assuming for the sake of an argument that approval u/s 153D of the Act is not valid ... therefore order of assessment u/s 153B(1)(b)/143(3) of the Act is a vitiated order which cannot be subject matter of revision u/s 263 of the Act. (iii) That the contention that order dated 18.12.2018 u/s 153B(1)(b)/143(3) of the Act is invalid

Pankaj Bansal, Gurgaon vs. Pr, CIT (Central), Gurgaon

In the result, ITA.No.383/Del

ITA 384/DEL/2021[2017-18]Status: DisposedITAT Delhi31 May 2021AY 2017-18

Bench: Shri Bhavnesh Saini & Shri O.P.Kant

For Appellant: And Shri Lalit Mohan, C.AFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153B(1)(b)Section 263

386/Del./2021 Smt. Abha Bansal, Sh Pankaj Bansal, Sh Basant Bansal And Sh Roop Kumar Bansal, Gurgaon. Act cannot be subject matter of revision u/s 263 of the Act. (ii) That without prejudice assuming for the sake of an argument that approval u/s 153D of the Act is not valid ... therefore order of assessment u/s 153B(1)(b)/143(3) of the Act is a vitiated order which cannot be subject matter of revision u/s 263 of the Act. (iii) That the contention that order dated 18.12.2018 u/s 153B(1)(b)/143(3) of the Act is invalid

Abha Bansal, Gurgaon vs. PCIT, Central, Gurgaon

In the result, ITA.No.383/Del

ITA 383/DEL/2021[2017-18]Status: DisposedITAT Delhi31 May 2021AY 2017-18

Bench: Shri Bhavnesh Saini & Shri O.P.Kant

For Appellant: And Shri Lalit Mohan, C.AFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153B(1)(b)Section 263

386/Del./2021 Smt. Abha Bansal, Sh Pankaj Bansal, Sh Basant Bansal And Sh Roop Kumar Bansal, Gurgaon. Act cannot be subject matter of revision u/s 263 of the Act. (ii) That without prejudice assuming for the sake of an argument that approval u/s 153D of the Act is not valid ... therefore order of assessment u/s 153B(1)(b)/143(3) of the Act is a vitiated order which cannot be subject matter of revision u/s 263 of the Act. (iii) That the contention that order dated 18.12.2018 u/s 153B(1)(b)/143(3) of the Act is invalid

Mikado Realtors (P) Ltd, New Delhi vs. Pr. CIT (Central), Gurugram

In the result, the appeal of the assessee is allowed

ITA 50/DEL/2021[2017-18]Status: DisposedITAT Delhi20 Apr 2021AY 2017-18

Bench: Shri Amit Shukla & Shri O.P. Kant

For Appellant: Shri Gautam Jain, Adv. & Shri LalitFor Respondent: Ms. Pramita M. Biswas, CIT-D.R
Section 142(1)Section 143(2)Section 143(3)Section 153BSection 153CSection 153C(1)Section 263

assessment dated 18.12.2018 u/s 153B(l)(b)/143(3) of the Act was without jurisdiction and therefore the same could not be validly revised u/s 263 of the Act 4.1 That the finding that “on perusal of the assessment record it is noted that during the assessment proceedings notice u/s ... opinion that there was application of mind by the AO and JCIT therefore the order of assessment dated 18.12.2018 could not be revised u/s 263 of the Act. 6.1 That finding of learned Principal Commissioner of Income Tax that “without prejudice of the above, since the AO and the JCIT

M/S. Kalinga Conduits Electricables (P) Ltd., New Delhi vs. Pr. CIT- 9, New Delhi

In the result, the appeal filed by the assessee is allowed

ITA 3287/DEL/2017[2010-11]Status: DisposedITAT Delhi24 Mar 2021AY 2010-11

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaassessment Year: 2010-11 Kalinga Conduits Electricables (P) Vs Pr. Cit-9, Ltd., New Delhi. 81/41, Punjabi Bagh West, New Delhi. Pan : Aacck5784H (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate; Shri Rajiv Sabharwal, Ca; & Shri Lalit Mohan, Ca. Revenue By : Mrs. Aashna Paul, Cit-Dr Date Of Hearing : 18.02.2021 Date Of Pronouncement : 24.03.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23Rd March, 2017 Passed U/S 263 Of The It Act, 1961 By The Pcit, New Delhi, Relating To The Assessment Year 2010-11. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company & Filed Its Return Of Income On 30Th September, 2010 Declaring An Income Of Rs.5,940/-. The Said Return Was Processed U/S 143(1) Of The Act. Subsequently, The Cit-Ii, New Delhi, Vide His Letter No. File 148/2012-13/2817 Dated 15Th March, 2013, Forwarded The Letter Of Investigation Ii, Delhi, Vide F. No.Dit (Inv.)-Ii/U/S 148/2012-13/197 Dated 12Th March, 2013 Giving Information About An Accommodation Entry Of Rs.40 Lakhs Received By The Assessee From M/S Victory Software Pvt. Ltd., Zenith Automotive Pvt. Ltd. & Humtum Marketing Pvt. Ltd. Based On The Above, The Ao Issued Notice U/S 148 After Recording The Reasons.

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Mrs. Aashna Paul, CIT-DR
Section 143(1)Section 143(2)Section 147Section 148Section 263

order passed u/s 147/143(3) of the Act for A.Y. 2010-11 in case of the assessee which is subject matter of revision u/s 263. He submitted that there was a long gap between the date of reopening of the assessment and date of completion of assessment u/s 147/143

Ace Infracity Developers P.Ltd, Ghaziabad vs. DCIT, Central Circle, Noida

The appeal of the assessee is allowed

ITA 1087/DEL/2018[2015-16]Status: DisposedITAT Delhi05 Mar 2021AY 2015-16

Bench: Ms Suchitra Kamble & Dr. B. R. R. Kumar

Section 115BSection 132Section 2Section 69

does not have any jurisdiction over those issues which have not been considered by the AO because they will be subject matter of revision u/s 263 or reassessment u/s 147. If CIT(A) tries to examine those issues which have not been considered by the AO, sec. 147 as well