2024 (5) TMI 33

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....avanan For the Petitioner : Mr. N. Ramakrishnan for M/s. ARK Law Associates For the Respondents : Mr. N. Dilip Kumar Senior Standing Counsel Assisted by Mr. K. Prabhu Junior Standing Counsel ORDER The petitioner has challenged the impugned order passed by the first respondent on 24.03.2022 under Section 263 of the Income Tax Act, 1961. The impugned order has preceded a show cause notice dated ....

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.... open for the first respondent to invoke Section 263 of the Income Tax Act, 1961, seeking revision of the assessment order passed on 30.12.2019 under Section 143(3) of the Income Tax Act, 1961. 5. The Writ Petition is opposed primarily on the ground that the petitioner had an alternate remedy before the appellate Tribunal under Section 253(1)(c) of the Income Tax Act, 1961. That apart, it is subm....

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....019 under the mechanism followed under CASS. 7. It is submitted that ample power is vested with the authorities wherever the authorities find that an assessment order passed is erroneous and prejudicial to the interest of the revenue. It is submitted that in this case, the scrutiny assessment order dated 30.12.2019 that was both erroneous and prejudicial to the interest of the revenue and thus, t....

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....19 under Section 143(3) of the Income Tax Act, 1961, for the Assessment Year 2017-2018. It is, in this background, the show cause notice was issued under Section 263 of the Income Tax Act, 1961. 11. The scrutiny assessment order passed under Section 143(3) of the Income Tax Act, 1961, cannot be confused with the impugned order dated 24.03.2022, pursuant to invocation of power under Section 263 of....