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    <title>2025 (8) TMI 132 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad set aside the revision order passed under section 263, holding that the issues on which the assessment order was found erroneous had already been decided in favor of the assessee by the ITAT in earlier years. The tribunal noted that the PCIT was aware of these prior decisions but still held the assessment order erroneous solely because the department disagreed with the ITAT&#039;s rulings, which was deemed a disregard of judicial hierarchy. Consequently, the revision order was quashed and the assessee&#039;s appeal allowed.</description>
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      <title>2025 (8) TMI 132 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=775945</link>
      <description>The ITAT Ahmedabad set aside the revision order passed under section 263, holding that the issues on which the assessment order was found erroneous had already been decided in favor of the assessee by the ITAT in earlier years. The tribunal noted that the PCIT was aware of these prior decisions but still held the assessment order erroneous solely because the department disagreed with the ITAT&#039;s rulings, which was deemed a disregard of judicial hierarchy. Consequently, the revision order was quashed and the assessee&#039;s appeal allowed.</description>
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