DCIT, CC-I, CHANDIGARH , CHANDIGARH vs. VALCO INDUSTRIES LTD., , CHANDIGARH

In the result, the appeal of the Revenue is dismissed

Bench: The Hon'Ble Punjab & Haryana High Court? Ii) Whether On The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) Is Right Holding Such Consequential Order As Void An Initio Ignoring The Facts That Order Passed By Ld. Pcit (Central), Gurugram U/S 263 Has Not Attained Its Finality? Iii) Whether On The Facts & In Circumstances Of The Case & In Law, The Ld. Cit(A) Was Right In Holding That Consequential Order Passed U/S 147 R.W.S. 263 Of The Act As Void As Initio Without Giving Any Liberty To The Revenue To Revive The Proceedings Consequent To Any Directions Or Order

801 of the Act were very much subject matter of the appeal in relation to the income which was disallowed by the Assessing Officer. On the ground of merger, the Court held that the Commissioner could not have exercised the revisional powers. The Hon'ble Gujarat High Court further held as under: "17. Thus, the Commissioner of Income