Earlier Section 263 Action Cannot Justify Fresh 153C Assessment

JCIT (OSD) Vs Narendra Aggarwal (ITAT Delhi) No Incriminating Material, Wrong Year & Consolidated Satisfaction – Delhi ITAT Upholds Quashing of 153C Assessment Despite Earlier 263 Proceedings Delhi ITAT, Delhi Bench ‘E’, in JCIT (OSD) Vs Narendra Aggarwal (ITA No.1017/Del/2025; AY 2015-16; order dated 19-12-2025), dismissed the Revenue’s appeal and upheld the CIT(A)’s order quashing the assessment framed u/s 153C r.w.s. 143(3). The Tribunal held that assumption of jurisdiction itself was invalid on multiple, independent grounds. The Tribunal noted that AY 2015-16 was a comple...