Section 263 Jurisdiction not invocable when Re-Assessment was Illegal

SBS Realtors Private Limited Vs ITO (ITAT Delhi) Learned Counsel for the Assessee submitted that since the re-assessment order is illegal and bad in Law and is covered by the Order of the Tribunal Dated 01.04.2019 in the case of assessee on the same issue, therefore, the Learned Pr. CIT cannot exercise jurisdiction under section 263 of the I.T. Act, 1961 in collateral proceedings. Therefore, the Order passed by the Learned Pr. CIT under section 263 of the I. T. Act, 1961 is invalid and bad in Law.  On the other hand, the Ld. D.R. relied upon the impugned Order of the Learned Pr. CIT and submi...