https://www.taxtmi.com/caselaws?id=449998 The ITAT Delhi held that a revision order u/s 263 by CIT against reopening of assessment was invalid. The AO had recorded reasons for reopening assessment regarding capital gains, bank deposits, and deduction u/s 54, but made no additions in reassessment proceedings. Since the AO failed to make additions for the very reasons that formed the basis of reopening belief, the reassessment order was unsustainable. Consequently, any revision order u/s 263 seeking to revise such unsustainable order cannot be accepted. The assessment order was deemed not erroneous, and CIT lacked jurisdiction under Section 263. The assessee's appeal was allowed. en-us Tue, 20 Feb 2024 00:00:00 +0530 Fri, 23 Feb 2024 09:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449998 The ITAT Delhi held that a revision order u/s 263 by CIT against reopening of assessment was invalid. The AO had recorded reasons for reopening assessment regarding capital gains, bank deposits, and deduction u/s 54, but made no additions in reassessment proceedings. Since the AO failed to make additions for the very reasons that formed the basis of reopening belief, the reassessment order was unsustainable. Consequently, any revision order u/s 263 seeking to revise such unsustainable order cannot be accepted. The assessment order was deemed not erroneous, and CIT lacked jurisdiction under Section 263. The assessee's appeal was allowed. Case-Laws Income Tax Tue, 20 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449998