Question And Answer
Subject: 263 Revision
Querist: bs
Answered by:
Tags: , , , ,
Date: January 13, 2023
Query asked by bs

After ITAT quashed order u/s 263 passed by pcit , AO issues notice u/s 154 on same point, what can be the remedy with Assessee?

Does it partake contempt of order of ITAT ? any case law?

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The facts of the case would have to be studied. Where proceedings under section 263 of the Act were quashed because the Ld. AO has taken a view which is a possible view, merely because it is prejudicial to the interest of the revenue would not result in revisionary proceedings. Since the Ld. Ao has taken a possible view, taking a new view would amount to a change of opinion. The scope of rectification under Section 154 of the Act is limited to only mistakes apparent from the record and a debatable issue is not a mistake apparent from the record.

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