Tribunal held that Commissioner could not take cognizance of an issue which had already attained finality in regular assessment. However as regards where no enquiry was made to as regards gift , revision is held to be valid . (AY. 2011-12)
Dev Raj Garg v PCIT ( 2019) 76 ITR 9/ 202 TTJ 1138/(2020) 185 DTR 130 ( Chd) (Trib)
S. 263 : Commissioner – Revision of orders prejudicial to revenue – Commissioner could not take cognizance of an issue which had already attained finality in regular assessment- Where no enquiry was made to as regards gift , revision is held to be valid . [ S.56(2), 147 ].