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2021 Supreme(Online)(ITAT) 7070

INCOME TAX APPELLATE TRIBUNAL (RAIPUR BENCH)
SHRI SHAKTIDHAM INFRAVENTURE PRIVATE LIMITED BILASPUR – Appellant
Versus
PR. COMMISSIONER OF INCOME TAX BILASPUR – Respondent


ORDER 

PER PRADIP KUMAR KEDIA - AM:

The captioned appeal has been filed at the instance of the assessee against the order of the Principal Commissioner of Income Tax, Bilaspur (‘PCIT’ in short), dated 31.03.2020 passed under s.263 of the Income Tax Act, 1961 (the Act) whereby the assessment order passed by the Assessing Officer (AO) dated 20.04.2017 under s. 143(3) of the Act concerning AY 2015-16 was sought to be set aside for reframing assessment in terms of supervisory directions.

2. As per the grounds of appeal, the assessee has sought to challenge the jurisdiction assumed by the PCIT under s.263 of the Act and as a corollary, sought to impugn the revisional order passed by the PCIT under s.263 of the Act.

3. The PCIT sought to revise the assessment order dated 20.04.2017 passed under s.143(3) of the Act by way of a show cause notice dated 26.02.2020 served upon the assessee, which is reproduced hereunder:

“Subject: Notice for Hearing in respect of Revision proceedings u/sec 263 of the THE INCOME TAX ACT, 1961 – Year 2015-16 In this regard, a hearing in the matter is fixed on 05/03/2020 at 04:30 PM. You are requested to attend in person or through an authorised representative and fi

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