Held that Order passed after getting approval from Joint Commissioner, after examining the documents, addition made on third-party based on documents and recorded statements, third party order is not revised which will lead to double taxation referred documents not of impugned assessment year or not belonging to assessee, hence revision order is not valid.(AY.2015-16 to 2018-19)
Gyan Infrabuild P. Ltd. v. PCIT (2024)114 ITR 184/230 TTJ 273/ 239 DTR 265 (Pat)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Search and Seizure-Order passed after getting approval from Joint Commissioner-Order passed after examining the documents-Addition made on third-party based on documents and recorded statements-Third party order is not revised-Double taxation–Referred documents not of impugned assessment year or not belonging to assessee-Revision order is not valid. [S.133A 153A, 153B]
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