Mumbai ITAT: PCIT Cannot Invoke Section 263 on Issues Already Pending Before CIT(A)

Advertisement M P Trading Company Vs PCIT (ITAT Mumbai) Mumbai ITAT: PCIT Cannot Invoke Section 263 on Issues Already Pending Before CIT(A) The Mumbai ITAT quashed the revisionary order passed under section 263, holding that the Principal Commissioner cannot exercise revisionary jurisdiction on issues which are already the subject matter of an appeal before the CIT(A). The Tribunal held that clause (c) of Explanation 1 to section 263 creates a statutory bar against such revision. The assessee’s assessment had originally resulted in an addition of 25% of alleged non-genuine purchases f...