JUDGMENT :

M.R. Shah, J.

1. Feeling aggrieved and dissatisfied with the impugned judgment and order dated 03.07.2019 passed by the High Court of Judicature at Madras in Tax Case Appeal No.429 of 2019, by which the High Court has dismissed the said appeal preferred by the revenue and has confirmed the order dated 04.04.2013 passed by the learned Income Tax Appellate Tribunal (hereinafter referred to as the learned ITAT) in ITA No.2244/Mds/2012, the revenue has preferred the present appeal.

2. The facts leading to the present appeal in nutshell are as under:

2.1 The Assessing Officer (hereinafter referred to as the AO) passed an assessment order under Section 143 (3) of the Income Tax Act (hereinafter referred to as the Act) for the assessment year (AY) 200809 vide assessment order dated 30.12.2010. The Commissioner of Income Tax initiated revision proceeding under Section 263 of the Act to revise the assessment order passed by the learned Assessing Officer and issued a notice to the assessee respondent herein on 01.02.2012. The assessee – respondent herein filed written submissions on 07.03.2012 and 12.03.2012. That the learned Commissioner passed an order under Section 263 of the Act o