Section 263 Cannot Override 153D Approval: Revision Quashed as Jurisdictionally Flawed

Tarun Kumar Sahay (HUF) Vs PCIT (ITAT Delhi) Assessee was subjected to proceedings u/s 153C pursuant to search on Alankit Group. Assessment was completed u/s 153C on 04-03-2024 after obtaining statutory prior approval u/s 153D from the Addl. CIT. Thereafter, Ld. PCIT invoked revisionary jurisdiction u/s 263 alleging that issues forming part of earlier reasons recorded u/s 148 were not properly examined in assessment u/s 153C and held the order to be erroneous & prejudicial to the interest of Revenue. ITAT quashed the revision. Tribunal held that once an assessment u/s 153C is passed after ...