https://www.taxtmi.com/caselaws?id=459653 The HC upheld the ITAT's decision, dismissing the revenue's appeal. It confirmed that the PCIT's exercise of jurisdiction under Section 263 of the Income Tax Act, 1961, was barred by limitation. The Court also endorsed the Tribunal's application of the doctrine of merger, finding the PCIT's actions legally untenable. The substantial questions of law were resolved against the revenue, affirming the Tribunal's interpretation of jurisdictional limits and procedural doctrines. en-us Mon, 17 Jul 2023 00:00:00 +0530 Fri, 20 Dec 2024 19:51:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459653 The HC upheld the ITAT's decision, dismissing the revenue's appeal. It confirmed that the PCIT's exercise of jurisdiction under Section 263 of the Income Tax Act, 1961, was barred by limitation. The Court also endorsed the Tribunal's application of the doctrine of merger, finding the PCIT's actions legally untenable. The substantial questions of law were resolved against the revenue, affirming the Tribunal's interpretation of jurisdictional limits and procedural doctrines. Case-Laws Income Tax Mon, 17 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459653