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35. Pr.CIT v. The Bombay Dyeing and Manufacturing Co. Ltd.: (2026) (9) TMI 872 (Bom):
A. Y. 2015-16: Date of order 28/08/2026:
S. 263 of ITA 1961
Revision of orders under section. 263 — Order passed under section. 263 quashed by the Tribunal — Appeal filed by the Department before the High Court — Pending the appeal before the High Court, assessment order passed by the AO under section. 143(3) r.w.s. 263 — Assessee’s appeal against the assessment order allowed — Department’s appeal dismissed by the Tribunal — Held that an assessment made pursuant to a revision order cannot survive after the revision order has been quashed — The fact that Department has challenged the quashing of 263 order before the High Court shall not come in the way.
An order dated 18/03/2020 was passed under section. 263 of the Act which was challenged before the Tribunal. The Tribunal quashed the order of the Principal Commissioner passed under section. 263 of the Act. Despite the fact that the Tribunal quashed the order of the Principal Commissioner under section. 263 of the Act, the Assessing Officer passed a consequential order under section. 143(3) r.w.s. 263 of the Act.
The assessee challenged the as
