Respected Sir,
\nIn response to Form 1 & 2 filed by the declarant, PCIT issued Form 3 in December,20. The Declarant paid taxes accordingly. On 10th March,21, PCIT uploaded the revised Form 3 determining liability @ 125% invoking FAQ 70. <\/p>\n
Q1:- Whether PCIT has power to revise Certificate issued due to CHANGE OF OPINION?<\/p>\n
Subsequently on 24th March, 2021, the declarant made submission to restore original Form 3in terms of modification (clarification)of FAQ 70 since declarant case was neither covered under search or survey nor assessment was made thereunder.Further, in an identical case of the declarant, the Hon.Bombay HC has allowed the petition in the matter of Bhupendra Harilal Mehta V PCIT 19 (same PCIT of Querist). Till now PCIT has not revised and restored original Form 3.<\/p>\n
Q2: Kindly suggest remedy.<\/p>\n
Q3: Is it not contempt of the court for not following jurisdictional court order?<\/p>\n","protected":false},"excerpt":{"rendered":"
Respected Sir, In response to Form 1 & 2 filed by the declarant, PCIT issued Form 3 in December,20. The Declarant paid taxes accordingly. On 10th March,21, PCIT uploaded the revised Form 3 determining liability @ 125% invoking FAQ 70. Q1:- Whether PCIT has power to revise Certificate issued due to CHANGE OF OPINION? Subsequently on 24th March, 2021, the declarant made submission to restore original Form 3in terms of modification (clarification)of FAQ 70 since declarant case was neither covered under search or survey nor assessment was made thereunder.Further, in an identical case of the declarant, the Hon.Bombay HC has allowed the petition in the matter of Bhupendra Harilal Mehta V PCIT 19 (same PCIT of Querist). Till now PCIT has not revised and restored original Form 3. Q2: Kindly suggest remedy. Q3: Is it not contempt of the court for not following jurisdictional court order?<\/p>\n