Answers On Topic: Revision of orders prejudicial to revenue
  Regarding reopening of case after period mentioned in 148
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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  protective assessments
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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  263-Commissioner – Revision of orders prejudicial to revenue
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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  revision procedings u/s 263- assessment
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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  reassesment u/s 147 when CIT exercises revisonal powers
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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  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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