https://www.taxtmi.com/caselaws?id=761324 The ITAT Nagpur quashed a revision order passed under section 263, holding that the Commissioner cannot invoke revision powers on issues entirely different from those forming the basis of reassessment proceedings under section 147. The Assessing Officer had conducted proper enquiry during reassessment based on recorded reasons and accepted the returned income without additions. The Commissioner's attempt to direct enquiry on independent issues not covered in the original reasons was deemed impermissible circumvention of statutory provisions. The revision order was struck down as bad in law, applying the principle that when the foundation is removed, the superstructure falls. en-us Tue, 22 Oct 2024 00:00:00 +0530 Fri, 08 Nov 2024 19:58:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761324 The ITAT Nagpur quashed a revision order passed under section 263, holding that the Commissioner cannot invoke revision powers on issues entirely different from those forming the basis of reassessment proceedings under section 147. The Assessing Officer had conducted proper enquiry during reassessment based on recorded reasons and accepted the returned income without additions. The Commissioner's attempt to direct enquiry on independent issues not covered in the original reasons was deemed impermissible circumvention of statutory provisions. The revision order was struck down as bad in law, applying the principle that when the foundation is removed, the superstructure falls. Case-Laws Income Tax Tue, 22 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761324