Reassessment Based on Quashed 263 Cannot Survive – Revenue Appeal Dismissed

ITO Vs Pantime Finance Company Pvt Ltd (ITAT Mumbai) ITAT Mumbai upheld CIT(A)’s order deleting additions made pursuant to a revision u/s 263, holding that once the base revision order itself is quashed by Tribunal, all consequential proceedings automatically fail. The reassessment order passed u/s 147 r.w.s. 263 & 144B had added substantial income after PCIT invoked revision alleging lack of enquiry and non-compliance with penny stock SOP guidelines. Tribunal noted that earlier co-ordinate bench had already quashed the revision order u/s 263 on both legal and factual grounds, including ...