https://www.taxtmi.com/caselaws?id=764589 ITAT Delhi ruled in favor of the assessee, holding that PCIT cannot exercise revision powers under section 263 when the same issue is pending before CIT(A). The case involved unpaid TDS on payments to a finance company, where PCIT sought to revise the assessment order for 30% disallowance under section 40(a)(ia). The tribunal found that clause (c) of Explanation 1 to section 263 bars revision proceedings when an appeal is pending before CIT(A), as CIT(A) has co-terminus powers with the Assessing Officer and can address the same issues. en-us Fri, 10 Jan 2025 00:00:00 +0530 Mon, 13 Jan 2025 14:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764589 ITAT Delhi ruled in favor of the assessee, holding that PCIT cannot exercise revision powers under section 263 when the same issue is pending before CIT(A). The case involved unpaid TDS on payments to a finance company, where PCIT sought to revise the assessment order for 30% disallowance under section 40(a)(ia). The tribunal found that clause (c) of Explanation 1 to section 263 bars revision proceedings when an appeal is pending before CIT(A), as CIT(A) has co-terminus powers with the Assessing Officer and can address the same issues. Case-Laws Income Tax Fri, 10 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764589