https://www.taxtmi.com/caselaws?id=427384 Revision under section 263 was held not to be maintainable where the underlying assessment dispute had already been settled under the Direct Tax Dispute Resolution Scheme, 2016 and Form 5 had been issued. The text states that the scheme conferred immunity against reopening the same controversy through revisionary proceedings, so the Principal Commissioner could not treat the assessment as erroneous and prejudicial on the same facts. It also notes that the Assessing Officer had taken a possible view after inquiry and that revision could not rest on a mere change of opinion. The settled dispute covered both the addition and the related jurisdictional challenge, so section 263 could not be invoked again. en-us Tue, 28 Jun 2022 00:00:00 +0530 Thu, 08 Sep 2022 07:22:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427384 Revision under section 263 was held not to be maintainable where the underlying assessment dispute had already been settled under the Direct Tax Dispute Resolution Scheme, 2016 and Form 5 had been issued. The text states that the scheme conferred immunity against reopening the same controversy through revisionary proceedings, so the Principal Commissioner could not treat the assessment as erroneous and prejudicial on the same facts. It also notes that the Assessing Officer had taken a possible view after inquiry and that revision could not rest on a mere change of opinion. The settled dispute covered both the addition and the related jurisdictional challenge, so section 263 could not be invoked again. Case-Laws Income Tax Tue, 28 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427384