PCIT Lacks Jurisdiction to Revise Assessment Order u/s 263 When TDS Issue Is Under CIT(A) Appeal.

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....The PCIT lacked jurisdiction to pass an order u/s 263 revising the assessment order when the issue of unpaid TDS was already the subject matter of an appeal before the CIT(A). As per Explanation 1(c) to s.263, the PCIT is barred from initiating revision proceedings when an appeal is pending before the CIT(A). The CIT(A)'s powers are co-terminus with the AO's, allowing redressal. The decisions in Smt. Renuka Philip, Golden Vats Pvt. Ltd., and CIT vs. Shalimar Housing affirmed this statutory bar on the PCIT's revisionary jurisdiction when the matter is already under appeal before the CIT(A). The assessee's case was decided in their favor.....