Lack of opportunity renders Section 263 revisional order a nullity

Smt. Shardaben B. Patel Vs Pr. CIT (ITAT Ahmedabad)

The revisional action under Section 263 of the Act in unsustainable in law on two counts; (i) A revisional action which began with a nondescript notice and culminated in revisional order without any effective opportunity despite specific request is an order passed in blatant transgression of natural justice & (ii) The Revisional CIT made an unflinching and adverse conclusion in the league of finality (without granting any opportunity) and closed the door for the assesse

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