Mahindra and Mahindra Ltd. v. ACIT (2025) 302 Taxman 551 (Bom.)(HC)

S. 151 : Reassessment-Sanction for issue of notice-Pendency of proceedings till proceeding before Appellate Authority or Revisionary Authority are decided, assessment order and further proceedings are stayed.[S.151A,246A 264, Art. 226]

On Writ  the Court held that  the assessee  has already filed an appeal against impugned order, as also assessee had filed a review application before Principal Chief Commissioner under section 264.Accordingly  the  assessee is directed to pursue the pending proceedings before appropriate Appellate Authority instead of filing instant writ petition. Till proceeding before Appellate Authority or Revisionary Authority are decided, assessment order shall remain stayed.   (AY. 2021-22)

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