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Judgment
This assessee’s appeal for Assessment Year 2018-19 arises against the Principal Commissioner of Income T ax(Appeals) (for shor t, ‘PCIT (A)’), Rohtak’ s order dated 21.03.2025, passed in DIN & order No. ITBA/REV/F/R EV5 /2024-25/1074837297(1), involving proceedings u/s 147 r.w.s. 144B of the Inco me Tax Act, 1961; hereinafter referred to as, “the Act”.
Heard both the parties at length. Case file perused.
We notice at the outset that there is hardly a need for the tribunal to delve with the relevant factual matrix at length so far as the learned PCIT’s impugned action assuming section 263 revision jurisdiction for terming the Assessing Officer’s re-assessment framed on 30.03.2023 as erroneous one causing prejudice to interest of the revenue; is concerned. This is for the precise reason that the assessee’s yet another appeal ITA no. 7515/Del/2025 heard and decided on 28.04.2026 has already got the impugned reopening quashed as a non-est one in the eyes of law which renders the PCIT’s section 263 revision proceedings has having not legs to stand going by Sublato fundamento cadit opus. We accept the assessee’s instant sole substantive ground in very terms.
All other pleadings between the parties on merits stand rendered academic.
This assessee’s appeal is allowed.