https://www.taxtmi.com/caselaws?id=771436 ITAT Ahmedabad allowed the assessee's appeal against PCIT's revision order u/s 263. The PCIT had initiated revision proceedings claiming the AO's assessment order was erroneous for not adding commission paid for arranging accommodation entries from shell companies. However, since CIT(A) had already held the share capital genuine and deleted the addition in appeal proceedings, the Tribunal applied the doctrine of merger. Following Bombay HC precedent, once assessment order merges with CIT(A)'s order, PCIT cannot exercise revisionary jurisdiction u/s 263 on the same matter. en-us Thu, 22 May 2025 00:00:00 +0530 Mon, 26 May 2025 08:52:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771436 ITAT Ahmedabad allowed the assessee's appeal against PCIT's revision order u/s 263. The PCIT had initiated revision proceedings claiming the AO's assessment order was erroneous for not adding commission paid for arranging accommodation entries from shell companies. However, since CIT(A) had already held the share capital genuine and deleted the addition in appeal proceedings, the Tribunal applied the doctrine of merger. Following Bombay HC precedent, once assessment order merges with CIT(A)'s order, PCIT cannot exercise revisionary jurisdiction u/s 263 on the same matter. Case-Laws Income Tax Thu, 22 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771436