Dy. CIT v. Brahma City Pvt. Ltd. (2022)98 ITR 451 (Delhi) (Trib)

S. 143(3) : Assessment-Validity-Assessment pursuant to revision order of CIT-Additions made with respect to issues out of the subject matter of revision order not justified-Deletion of addition. By CIT(A) is justified. [S. 263].

Held, that the Assessing Officer  was not empowered to expand the scope of consequential proceedings under section 143(3) read with section 263 of the Income-tax Act, 1961 by making assessment in respect of issues which were not subject matter of revisional order under section 263. The action of the Commissioner (Appeals) reversing the additions made by the Assessing Officer wholly unconnected to the directions given in the revisional order was thus in consonance with law delineated in judicial precedents and did not warrant any interference. (AY. 2014-15)