Second section 263 revision on same subject quashed by ITAT

Advertisement Amritrashi Infra Pvt Ltd Vs PCIT (ITAT Kolkata) Second revision u/s 263 quashed by ITAT holding not permissible on the same subject matter on which specific direction given by First PCIT have been complied by AO. Doctrine of merger applied. Aggrieved by the aforesaid action of the Second Ld Pr. CIT, Kol-4, now the assessee is before us. The question before us is twofold. Firstly, whether the second Ld. Pr. CIT satisfied the statutory condition-precedent as prescribed in section 263 of the Act before invoking the Revisionary Jurisdiction. Secondly, whether the Second Ld Pr. CIT...