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Gujarat State Electricity Corporation ... vs The Pr. Cit-1, Vadodara on 8 April, 2025

13. In view of the foregoing discussion, we are of the considered view that the assessment order is vitiated due to complete absence of inquiry on two material items having a substantial bearing on the determination of taxable income under the normal provisions of the Act. The explanations and accounting entries now furnished by the assessee were not subjected to verification during the original assessment and hence do not cure the error at the stage of revision. The PCIT was justified in invoking section 263 of the Act and directing the AO to reframe the assessment after examining the nature ITA No.572/Ahd/2020 Gujarat State Electricity Corporation Ltd. vs. Pr.CIT-1 Asst. Year : 2015-16 12 and allowability of the impugned items. The revisionary order is valid in law and does not suffer from any jurisdictional or procedural infirmity.
Income Tax Appellate Tribunal - Ahmedabad Cites 18 - Cited by 0 - Full Document

Gujarat State Electricity Corporation ... vs The Pr. Cit, Vadodara-1,, Baroda on 13 March, 2019

15. We, therefore, are clearly of the opinion that keeping in view the facts and circumstances of this case and, in particular, having regard to the fact that the CIT exercising its revisional jurisdiction reopened the order of assessment only in relation to lease equalization fund which being not the subject of the reassessment proceedings, the period of limitation provided for under sub-s. (2) of s. 263 of the Act would begin to run from the date of the order of assessment and not from the order of reassessment. The revisional jurisdiction ITA No.468/Ahd/2016 Gujarat State Electricity Corp. Ltd. vs. Pr.CIT-I Asst.Year - 2008-09 -9- having, thus, been invoked by the CIT beyond the period of limitation, it was wholly without jurisdiction rendering the entire proceeding a nullity.
Income Tax Appellate Tribunal - Ahmedabad Cites 15 - Cited by 0 - Full Document
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