Section 263 Revision invalid when assessment order merged with CIT(A)’s order

CIT Vs Slum Rehabilitation Authority (Bombay High Court) Conclusion: Revision under section 263 was invalid in case order of assessment merged with the order of Appellate CIT in its entirety as CIT did not have jurisdiction to revise such order of assessment in view of clause (c) of Expln. 1 to sub-section (1) of section 263. Held: Assessee – slum rehabilitation authority had filed return of income claiming benefit under Section 11 in relation to its income claiming itself to be engaged in charitable activity. AO passed an order of assessment under Section 143(3) in which this claim was ...