Assessment u/s 153A passed with prior approval u/s 153D cannot be revised

Tapadia Constructions Ltd. Vs PCIT (Central) (ITAT Pune)

Revision u/s 263 quashed – Assessment u/s 153A passed with prior approval u/s 153D cannot be revised; AO made due enquiry; mere valuation difference not a ground for 263

This appeal by Assessee arose from revision u/s 263, where PCIT held that AO failed to tax alleged undervaluation of building & plant/machinery based on a Sub-Registrar valuation report. AO had completed assessment u/s 153A r.w.s. 143(3) on 02.06.2021 after mandatory approval u/s 153D and had already examined valuation issues, ma

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