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Revision u/s 263 by CIT - the ITAT upheld the impugned order, dismissing the appeal of the assessee. The Tribunal ruled that the CIT had exercised revisional jurisdiction after independently examining the records and applying their mind to the case. Additionally, they found that the reference made by the Assessing Officer to the TPO was invalid due to the expiration of the time limit, making it no reference in the eyes of the law.
Revision u/s 263 by CIT - the ITAT upheld the impugned order, dismissing the appeal of the assessee. The Tribunal ruled that the CIT had exercised revisional jurisdiction after independently examining the records and applying their mind to the case. Additionally, they found that the reference made by the Assessing Officer to the TPO was invalid due to the expiration of the time limit, making it no reference in the eyes of the law.
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