Revisional order quashed, consequential assessment appeal became infructuous and was dismissed as no live controversy survived.

Once the revisional order under Section 263 of the Income-tax Act was quashed, the assessment order passed under Section 143(3) read with Section 263 and the connected Revenue appeal lost their foundation. The proceedings were entirely consequential to the revisional order, so its disappearance meant there was no surviving live controversy for adjudication. The ITAT Delhi accordingly treated the appeal as infructuous and dismissed it.

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Issues: Whether the Revenue's appeal against the order passed under Section 143(3) read with Section 263 of the Income-tax Act, 1961 survived after the revisional order under Section 263 had already been quashed.

Analysis: The appeal arose only from consequential proceedings undertaken pursuant to the revisional order under Section 263. Once that revisional order ceased to exist, the foundation for the assessment order and the connected appellate proceedings also fell away. The pending appeal, therefore, no longer presented a live controversy for adjudication.

Conclusion: The appeal was held to be infructuous and was dismissed.

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