ESOP expenditure allowed as FMV difference; long-term capital gain issue sent back for collector rate determination; deferred income additions disallo...
Appeal allowed; impugned order quashed as regulator failed to prove nexus or manipulative scheme; sale genuine - s.12A(a)-(c), Regs 3(a)-(d),4(1),4(2)...
ITAT allowed the assessee's appeal and quashed the revisionary order passed by PCIT u/s 263. It held that once the assessee opted for and finalized settlement under the Direct Tax Vivad Se Vishwas Act, 2020, the tax dispute stood conclusively closed and could not be reopened through revision proceedings u/s 263. Relying on binding HC precedent, ITAT concluded that the PCIT's exercise of jurisdiction was contrary to the scheme and object of the Vivad Se Vishwas Act, rendering the impugned revisional order unsustainable in law.
ITAT allowed the assessee's appeal and quashed the revisionary order passed by PCIT u/s 263. It held that once the assessee opted for and finalized settlement under the Direct Tax Vivad Se Vishwas Act, 2020, the tax dispute stood conclusively closed and could not be reopened through revision proceedings u/s 263. Relying on binding HC precedent, ITAT concluded that the PCIT's exercise of jurisdiction was contrary to the scheme and object of the Vivad Se Vishwas Act, rendering the impugned revisional order unsustainable in law.
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