Held that order passed by the Assessing Officer in accordance with directions issued by Dispute Resolution Panel, cannot be revised by Commissioner. Explanation 1(a) to section 263 clarifies that order of Assessing Officer in certain cases passed on direction of Superior Officers can be subject matter of section 263 but Explanation 1(a) to section 263 does not include order passed under direction of DRP under section 144C(13). (AY. 2013-14)
Barclays Bank PLC v. CIT (IT) (2022) 215 TTJ 965 /212 DTR 33 / 139 taxmann.com 503 (Mum)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Dispute Resolution Panel-Order passed by the Assessing Officer passed order in accordance with directions issued by DRP, same cannot be revised by Commissioner. [S. 144C(13)]