PCIT Cannot Revise U/s 153C Order Without First Upsetting U/s 153D Approval

Alka Agarwal Vs PCIT (ITAT Delhi) Assessee’s case was originally reopened u/s 148 on allegations of bogus accommodation entries & penny stock gains. Subsequently, pursuant to search in Alankit Group, proceedings were initiated u/s 153C and reassessment u/s 148 stood abated. AO completed assessment u/s 153C after obtaining statutory approval u/s 153D from Addl. CIT and made additions on account of alleged bogus LTCG, cash payments for property and commission income. PCIT invoked revisionary jurisdiction u/s 263 on the ground that issues for which reopening u/s 148 was initiated were not p...