The PCIT passed the revision order in respect of claim u/s 80IA which was allowed in the original assessment proceedings by the Assessment order u/s 143(3) dt 28-3-2016. Due to search action proceedings were initiated u/s 153C of the Act. The claim of section 80IA was not subject matter of proceedings u/s. 153C of the Act. Revision order was passed on 19-12-2020. The Tribunal held that the revision order is barred by limitation. (AY. 2013-14)
Seyad Shariat Finance Ltd. v. PCIT (2021) 206 DTR 282 / 91 ITR 4 (SN) / 213 TTJ 897 (Chennai)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limitation-Issue was not subject matter of assessment u/s 153C–Original order on 28-3-2016-Revision order passed on 9-12-2020-Barred by limitation. [S.80IA, 143(3), 153C]