Section 263 Order Quashed: Null Assessment Cannot Be Revised Under IBC

Reliance Projects And Property Management Services Limited Vs PCIT (ITAT Ahmedabad) Nullity Cannot Be Revised: When Assessment Itself Is Dead, Section 263 Cannot Revive It- IBC Resolution Plan Prevails: PCIT’s 263 Order Falls as Base Assessment Is Quashed by HC Assessee challenged two revision orders u/s 263 passed by PCIT for AYs 2018-19 & 2019-20. For AY 2019-20, assessment u/s 143(3) was completed on 28.09.2021 allowing depreciation on passive telecom infrastructure assets at fair value. PCIT held that depreciation ought to have been restricted to WDV of transferor company (RITL/RCOM ...