Filling of petition u/sec 264 for correcting mistakes happen at the time of filling of Return of Income

Assessee is partnership firm engaged in the business of construction and development of housing project. Assessee firm has filed the Return of Income for AY 2018-19, 2019-20 and 2020-21. While filling the Return of Income as per advice of CA, added back the difference in stamp duty valuation and actual consideration u/sec 43CA of the Act.  While making this disallowance, assessee firm has added the difference even though the same is less than 10%. Since the disallowance was huge, assessee firm has uploaded the Return with out making payment of self assessment tax. All the returns are processed u/143(1A) of…

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  When an order is passed u/s.153A, can it be revised by PCIT u/s.263 of the Act ?

once order is passed u/s 153A/C , can it be revised by PCIT u/s 263 ?

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  When earlier order is merged with subsequent order u/s 153A, whether revision of order is valid ?

Assessee's assessment order u/s 147 was subject to 263 proceedings . Subsequently search took place in assessee group company and assessment u/s 153A concluded without any adverse inference touching upon the issues which were subject matter of earlier 263 proceedings , although the AO was unaware of any such 263 proceedings. The assessment u/s 153A had attained finality & no 263 proceedings initiated by Department against such order . The earlier 263 order was challenged before ITAT which set aside the matter back to CIT for giving opportunity. Despite the CIT informed about subsequent 153A order which has merged &…

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