Section 263 Quashed in Search Case – PCIT Cannot Revise Without Touching U/s 153D Approval

Shashi Kant Damodar Khandelwal Vs PCIT (ITAT Mumbai) Mumbai ITAT quashed revision proceedings initiated under Section 263 across multiple years in a search-related case involving alleged accommodation entries linked to the Alankit Group. The Tribunal held that where assessments u/s 153C r.w.s. 143(3) are passed after mandatory approval u/s 153D, such approval becomes an integral part of the assessment order. Therefore, the PCIT cannot invoke Section 263 merely on the ground of inadequate enquiry without first examining or invalidating the 153D approval. It was further observed that the AO had ...