Section 263 Order Set Aside Where Underlying Section 153C Assessment Itself Is Time-Barred

Popatbhai Talashibhai Savani Vs PCIT (ITAT Surat) The Surat Bench of the ITAT allowed the assessee’s appeals for AYs 2013-14 and 2014-15 and quashed the revisionary orders passed under section 263. The Tribunal held that the very foundation of the Principal Commissioner’s action—namely, the assessment framed under section 143(3) read with section 153C—was legally unsustainable as it was barred by limitation. Relying on the Supreme Court decision in CIT v. Jasjit Singh, the Tribunal reiterated that in the case of an “other person” under section 153C, the six-year block period has to...