CA Lalit Kandoi (Chartered accountant) (1053 Points)
21 June 2012
GOPAL AGGARWAL
(DOING NOTHING)
(1339 Points)
Replied 21 June 2012
so far I know if matter goes in appeal than matters referred in appeal cannot be revised u/s 264
CA sanjeev goyal
(senior excutive)
(100 Points)
Replied 21 June 2012
mr gopal is right- beacuse the matter which has gone an appeal become merged and cannot be revised.
CA Lalit Kandoi
(Chartered accountant)
(1053 Points)
Replied 21 June 2012
But as u as per section 263, if appeal made to CIT(A) on certain matter
than on some other matter CIT can revise the order of AO u/s 263
CA sanjeev goyal
(senior excutive)
(100 Points)
Replied 21 June 2012
I m not very sure but it can be because of in sec 263 -concept of Partial merger is followed.
and in sec.264 concept of total merger is folowed.
CAclubindia
