https://www.taxtmi.com/caselaws?id=417414 The Tribunal held that the Second Principal Commissioner of Income Tax (Pr. CIT) did not satisfy the statutory condition precedent required under Section 263, rendering his invocation of revisional jurisdiction null and void. The Tribunal found that the Second AO conducted a proper inquiry into the share capital and premium, complying with specific directions from the First Pr. CIT. Additionally, the Tribunal emphasized that the doctrine of merger precluded the Second Pr. CIT from re-examining matters already decided by the First Pr. CIT. The Tribunal invalidated the Second Pr. CIT's reliance on Explanation 2(c) under Section 263, ultimately quashing the impugned order and ruling in favor of the assessee. en-us Fri, 07 Jan 2022 00:00:00 +0530 Sat, 22 Jan 2022 08:48:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=417414 The Tribunal held that the Second Principal Commissioner of Income Tax (Pr. CIT) did not satisfy the statutory condition precedent required under Section 263, rendering his invocation of revisional jurisdiction null and void. The Tribunal found that the Second AO conducted a proper inquiry into the share capital and premium, complying with specific directions from the First Pr. CIT. Additionally, the Tribunal emphasized that the doctrine of merger precluded the Second Pr. CIT from re-examining matters already decided by the First Pr. CIT. The Tribunal invalidated the Second Pr. CIT's reliance on Explanation 2(c) under Section 263, ultimately quashing the impugned order and ruling in favor of the assessee. Case-Laws Income Tax Fri, 07 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417414