Maintainability of writ against section 263 revision power, while appeal before CIT(A) is pending

Prestige Marketing Vs PCIT (Kerala High Court) Maintainability of writ against the revision power under section 263 of the Income Tax Act, while appeal before CIT A is pending Facts :- The petitioner has preferred a statutory appeal before the CIT(Appeals) on 15.1.2020. It is during the pendency of the appeal that the first respondent issued show cause notice dated 21.2.2022, to the petitioner on the finding that, out of the total addition of Rs. 3,35,33,509/- in Ext P1 A.O, only an amount of Rs. 68,25,000/- was taxed at the special rate under Sec. 69 read with Sec. 115BBE of the Act and balan...