The Tribunal held that the Assessing Officer ought not to have forwarded the proposal to the Principal Commissioner/Commissioner for revision of his own order if remedy was available with the Assessing Officer to rectify his mistake under section 154. The Principal Commissioner ought to have applied his own mind independently instead of initiating proceedings under section 263. It amounted to a miscarriage of justice. Revision was quashed. (AY.2013-14)
Gurfateh Films and Sippy Grewal Productions (P.) Ltd. v. PCIT (2022)95 ITR 456 (Amritsar)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Mismatch of disclosure of receipts-Income-Tax Return and Form 26AS-Assessee duly filing reply with necessary evidence-Assessing Officer sending proposal to Principal Commissioner on same issue-Amounts to miscarriage of justice-Revision order was quashed. [S. 154, Form, 26AS.]