Held that revision order is bad in law as the Reassessment order was passed without issuing the notice under section 143 (2) of the Act. When re assessment is without jurisdiction, revision order is without jurisdiction. Tribunal also held that the order was passed after detailed investigation hence even on merit the revision is bad in law. (AY. 2019-20)
Garud Credit & Holding (P) Ltd. v. ITO (2023) 226 TTJ 989 (Kol)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue–Invalid assessment-Notice under section 143(2) is not served-Reassessment is bad in law-Issue of shares-Share capital-Order was passed after detailed investigation-Revision is bad in law.[ S. 56, 68, 143(2), 147, 148]