2025 (4) TMI 1972

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.... ORDER PER BENCH : This is an appeal filed by the assessee against the order passed by the ld PR. CIT, Sambalpur u/s.263 of the Income Tax Act, 1961 for the assessment year 2014-15 in DIN & Order No. ITBA/REV/F/REV5/2023-24/1060101431(1). 2. It was submitted by ld AR that before the ld Pr. CIT, Sambalpur, in response to show cause notice u/s.263 of the Act, the assessee had categorically....

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....e Act has been issued only on 01.04.2021 which is evidenced by the assessment proceedings order sheet notings which has been extracted above. It was submitted that consequently as the assessment proceedings is itself bad in law, the consequential proceedings u/s 263 are liable to set aside. 4. In reply ld CIT DR vehemently supported the order of the Pr. CIT. It was the submission that the notic....

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....n 1.04.2021. Admittedly, this notice issued itself would be bad in law and consequential assessment order would be bad in law. Obviously, once the assessment order itself is bad in law, the revisionary proceedings u/s 263 passed by the Pr. CIT on such invalid assessment order would also be bad in law. In these circumstances, the order passed u/s 263 by the Pr. CIT in the case of the assessee for t....

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....ce/Letter pdf Notice/ Communication Reference ID : 100046790575 Notice u/s ITBA/AST/F/17/2021- 22/1041359415(1) Document reference ID Description : DTBA]lesue Letter Issued On : 23-Mar-2022 View Response Notice/Letter pdf Notice/ Communication Reference ID : 100042454261 e-Filing Anywhere Anyüne Income Tax Department, Govemmert of india ------ 8 14:1 5 9 ®....