Section 263 of Income Tax Act, 1961— re-opening of assessment— In the instant case, only effective grievance is this that the impugned order passed by the learned PCIT is without jurisdiction.

Held that—In our considered opinion, under these facts, this Judgment of Hon’ble Madras High Court rendered in the case of CWT vs. Sampathmal Chordia (Supra) is applicable and respectfully following the same, we hold that learned PCIT had no jurisdiction u/s 263 in the facts of the present case and hence, we set aside the impugned order passed by PCIT u/s 263 of I. T. Act, 1961.[M/S VSL STEELS LIMITED VERSUS DCIT, CIRCLE – 2 (3) , BENGALURU, PCIT – 7, BENGALURU] [2019] 20 ITCD Online (20) [ITAT BANGALORE]