Flawed Income Tax Assessment Order Cannot Be Revised Through Section 263 Revision

Mikado Realtors P. Ltd. Vs PCIT (ITAT Delhi)

The appeal in question was filed by Mikado Realtors P. Ltd. against the order dated 24th December 2020 passed by the Principal Commissioner of Income Tax (PCIT) under Section 263 of the Income Tax Act. The assessee raised multiple grounds, primarily challenging the PCIT’s jurisdiction and the validity of the revisionary order. The key issue revolved around the assertion that the assessment order dated 18th December 2018 was not subject to revision, as it was issued without jurisdiction. The assessee contended that the original order wa

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