Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
ITAT held that revisionary proceedings under Section 263 cannot be initiated for matters already considered and decided in appeal by CIT(A). In this case, the alleged bogus share capital was deemed genuine by CIT(A), thus precluding further revisional action. Relying on precedent from Bombay HC in Slum Rehabilitation Authority, the Tribunal applied the doctrine of merger, which prevents reassessment of issues already adjudicated in appellate proceedings. The PCIT's attempt to reopen the assessment was deemed improper, as the original assessment order had merged with CIT(A)'s order. Consequently, the assessee's appeal was allowed, effectively nullifying the revisionary proceedings.
ITAT held that revisionary proceedings under Section 263 cannot be initiated for matters already considered and decided in appeal by CIT(A). In this case, the alleged bogus share capital was deemed genuine by CIT(A), thus precluding further revisional action. Relying on precedent from Bombay HC in Slum Rehabilitation Authority, the Tribunal applied the doctrine of merger, which prevents reassessment of issues already adjudicated in appellate proceedings. The PCIT's attempt to reopen the assessment was deemed improper, as the original assessment order had merged with CIT(A)'s order. Consequently, the assessee's appeal was allowed, effectively nullifying the revisionary proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
