Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.58/Srt/2022 "नधा"रणवष"/Assessment Year: (2017-18) (Physical Court Hearing) Siddhi Vinayak Knots & Prints Pvt. Ltd. Vs. The Pcit-2, A-26, Central Park, Gidc, Pandesara Surat. S.O., Pandesara, Surat-394221. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamcs4421L

255 (SC), it was held that the order u/s. 263 is not valid as when PCIT passed the order, the decision of jurisdictional High Court in the favour of the assessee was available which was turned down by the Supreme Court subsequently. In the case of the assessee, the decisions of the Supreme Court were available in assessee’s favour