Answers On Topic: Revision of orders prejudicial to revenue
Notice u/s 148 was issued on 05.04.2022 for A.Y 2018-19 after completing the formalities of issue of notice u/s 148A(b) and order u/s 148A(d). The assessment was going on. In the meantime assessee received notice u/s 153C dt 18.01.2023 in a search matter conducted on 20.10.2019 and therefore proceeding u/s 148 got abated. AO pass the assessment order u/s 153C on 13.02.2024 at returned income. Thereafter assesse received notice u/s 263 from CIT mentioning that AO has not discussed the issue raised while opening case u/s 148. It is also alleged that he did not make any inquiry about matter…
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what are the effects, if no appeals are filed in such cases of protective assessments? is 263 possible in such cases?
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Can ITAT decline to hear appeal against order u/s 263 just because another order u/s 143[3] r w s 263 is passed making those additions ?
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sir, During assessment proceedings , consequent to revision u/s 263 , the range additional commissioner of income tax has issued directions u/s 144A of the Act, whether the addl commisioner action in issuing directions to the concerned assessing officer is valid in law , he issued letter to the assesse for hearing. further , the additional commissioner of income tax issued letters to the partners of the assessee for hearing . pl guide me and any relevant case law
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Sir, In one case, the CIT u/s 263 has set aside an assesssment u/s143(3) for a particular issue to be verfied by the assessing officer. However for the same assessment year, the assessing officer has re opened u/s 147 on another issue. Whether two proceedings is possible for same assesment year. How to proceed to re opening notice, pl advice
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once order is passed u/s 153A/C , can it be revised by PCIT u/s 263 ?
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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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Regarding reopening of case after period mentioned in 148