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    <title>2025 (1) TMI 1474 - ITAT JAIPUR</title>
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    <description>The ITAT Jaipur quashed revision proceedings u/s 263 against an assessee whose case was under protective assessment. The tribunal held that since the department had taken a firm stand against the primary assessee (Sh. Mahendra Mehra) and CIT(A) confirmed it as substantive assessment, the protective assessment against the current assessee became invalid. The tribunal ruled that simultaneous proceedings for the same matter and amount cannot continue once the department determines the actual liable person. Additionally, the PCIT&#039;s order was set aside for violating principles of natural justice by not considering the assessee&#039;s submissions, despite evidence showing proper replies were filed.</description>
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      <title>2025 (1) TMI 1474 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=765409</link>
      <description>The ITAT Jaipur quashed revision proceedings u/s 263 against an assessee whose case was under protective assessment. The tribunal held that since the department had taken a firm stand against the primary assessee (Sh. Mahendra Mehra) and CIT(A) confirmed it as substantive assessment, the protective assessment against the current assessee became invalid. The tribunal ruled that simultaneous proceedings for the same matter and amount cannot continue once the department determines the actual liable person. Additionally, the PCIT&#039;s order was set aside for violating principles of natural justice by not considering the assessee&#039;s submissions, despite evidence showing proper replies were filed.</description>
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