https://www.taxtmi.com/caselaws?id=771758 The ITAT Surat quashed a revision order passed u/s 263 against a reassessment order u/s 147 r.w.s. 144B involving penny stock trading allegations. The tribunal held that since the issues in reassessment proceedings (corpus donation) and revision proceedings (accumulation and application verification) were different in character, the doctrine of merger did not apply. The two-year limitation period for revision commenced from the intimation date u/s 143(1) on 10.11.2014, making the revision order time-barred under section 263(2). The assessee's appeal was allowed and the revision order was set aside. en-us Thu, 26 Dec 2024 00:00:00 +0530 Fri, 30 May 2025 08:55:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771758 The ITAT Surat quashed a revision order passed u/s 263 against a reassessment order u/s 147 r.w.s. 144B involving penny stock trading allegations. The tribunal held that since the issues in reassessment proceedings (corpus donation) and revision proceedings (accumulation and application verification) were different in character, the doctrine of merger did not apply. The two-year limitation period for revision commenced from the intimation date u/s 143(1) on 10.11.2014, making the revision order time-barred under section 263(2). The assessee's appeal was allowed and the revision order was set aside. Case-Laws Income Tax Thu, 26 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771758