My solution on DT (old) May 2010

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Question No.6(a)

The answer given by Mr.Ganshyam Joshi is absolutely correct. There is no bar nunder the Income-tax Act for parallel proceedings under section 147 and section 263. Both AO and CIT are empowered under different provisions of the Income-tax Act, although the objective of both the authorities is to ensure that there is no escapement of income from being taxed. However, if the order of the CIT is passed first, then the proceeding under section 147 initiated by the AO becomes infructuous and is to be dropped.

Different people different opinion. thats true with direct or indirect tax. Thanks

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