The assessee is advised to file an appeal before the Appellate Tribunal against , revision order . One has to read the recorded reasons and also direction of the PCIT . In CIT v. Neyveli Lignite Corporation Ltd ( 2020 ) 273 Taxman 322 ( Mad )( HC) the court held that , where Assessing Officer initiated reassessment proceedings on ground that assessee had raised excess claim of depreciation in respect of water supply and drainage system, in view of fact that said reason for reopening of assessment was subject matter of proceedings under section 143(3) and thereupon proceedings under section 263, once again, for very same reason, power under section 147 could not be invoked and, thus, impugned reassessment proceedings were to be set aside.
One has to read the direction of the Commissioner . Under the Act there is no bar for reopening the assessment more than once . However each time the revenue reopens the assessment it has to satisfy the requirement of the section 147 of the Act . Each case has to be tested on the facts of the case .