PCIT v. Bulbul Agrawal.(2025) 482 ITR 279 (SC) Editorial : PCIT v. Badal Prakash Jindal (HUF) (2023) 457 ITR 345 (Orissa)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue Reassessment-Finding of Tribunal that reasons supplied to assessee were not same reasons recorded and found in assessment record and that order of reassessment was not valid-Finding that since reassessment order itself was not validly passed, revision thereof by Principal Commissioner was invalid-SLP of revenue dismissed. [S. 147, 148 Art. 136]

The High Court held that the Tribunal had found that the reasons supplied to the assessee were not the same reasons recorded and found in the assessment record and that the order of reassessment was not valid, and that since the original reassessment order itself was not validly passed, the subsequent revision order by the Principal Commissioner was invalid. On SLP dismissing the petition, the Court held  that in view of the findings of fact recorded by the Tribunal in paragraphs 14 and 15 of its judgment which had been confirmed by the High Court, there was no case for interference under article 136 of the Constitution.(AY. 2013-14)

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