Sec 263 Invalid Where PCIT Didn’t Challenge Sec 153D Approval in 153C Case

SWD Industries Vs PCIT (Central) (ITAT Mumbai) Sec 263 Quashed – PCIT Cannot Revise U/s 153C Assessment Without Challenging U/s 153D Approval Search assessments u/s 153C r.w.s. 143(3) were completed after mandatory approval u/s 153D. PCIT invoked revision u/s 263 alleging lack of enquiry on accommodation entries based on Alankit group search material. ITAT held: Approval u/s 153D is not a mere formality; it is a statutory safeguard involving application of mind Once assessment is passed with such approval, it becomes integral part of assessment record PCIT must examine & dislodge validi...