SHIMLA PROPERTIES,LUCKNOW vs. PR. COMMISSIONER OF INCOME TAX, LUCKNOW
In the result, the appeal filed by the assessee is allowed
ITA 113/LKW/2022[2012-13]Status: DisposedITAT Lucknow01 Sept 2022AY 2012-13
Bench: Shri. A. D. Jain & Shri T. S. Kapoorassessment Year: 2012-13 Shimla Properties V. The Pcit 30C, Datiya House Lucknow Khursheed Bagh Lucknow Tan/Pan:Ablfs9732M (Appellant) (Respondent) Appellant By: Shri P. K. Kapoor, C.A. Respondent By: Shri Neeraj Kumar, Cit (Dr) Date Of Hearing: 16 08 2022 Date Of Pronouncement: 01 09 2022 O R D E R
For Appellant: Shri P. K. Kapoor, C.AFor Respondent: Shri Neeraj Kumar, CIT (DR)
Section 143(1)Section 147Section 263
u/s 147/143(3) of the Act, and accordingly the proceedings invoked under section 263
of the Act by the Ld. PCIT vide notice dated 18.1.2022 is barred by limitation and the order dated 17.3.2022 passed in consequence of the said notice is void-ab-initio.”
3. These Additional Grounds raise a legal issue going to the root of the matter