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13 Principal CIT vs. Techno Tracom Pvt. Ltd.
[2024] 461 ITR 47 (Cal.)
A.Y.: 2009–10
Date of order: 27th March, 2023
S. 263 of the ITA 1961
Revision — Powers of Commissioner — Power to consider assessment record — Meaning of record — Record includes all material including results of search proceedings — Order of revision without considering results of search proceedings — Not valid.
The original assessment in the case of the assessee for the A.Y. 2009–10 was completed u/s. 143(3) of the Income-tax Act, 1961 on 28th March, 2011. The Principal Commissioner exercised his jurisdiction u/s. 263 of the Act and passed the order dated 28th March, 2013. Prior to the order being passed u/s. 263 of the Act, a search and seizure operation was conducted on the assessee on 18th February, 2013. The assessee challenged the order passed u
