Second appeal dismissed: earlier adjudication bars re-litigation of s.2(22)(e) addition challenging double taxation; s.264 revision time-barred

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....ITAT upholds CIT(A)'s dismissal of the second appeal, concluding the taxpayer is barred from a separate appellate remedy against the same assessment order. The taxpayer's challenge to an addition under s.2(22)(e) as causing double taxation was not entertained because the first appeal against the assessment had been adjudicated on merits, precluding re-litigation by a subsequent appeal. The application for revision/rectification under s.264 filed after more than four years was time-barred and the PCIT's refusal to condone delay was not challenged. The Tribunal found the judicial authority relied upon inapposite where first appeals were dismissed on technical grounds, and accordingly dismissed the taxpayer's second appeal.....