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Income Tax - Highlights / Catch Notes

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ITAT held that the assessment order under sec. 153C was invalid ...


Income Tax Assessment Order Under Sec. 153C Invalidated Due to Insufficient Evidence and Improper Correlation of Search Materials

April 15, 2025

Case Laws     Income Tax     AT

ITAT held that the assessment order under sec. 153C was invalid due to lack of proper satisfaction regarding incriminating material. The AO failed to establish a direct correlation between search materials and the assessee's income for AY 2019-2020. Consequently, the PCIT's revisionary order under sec. 263 was deemed illegal and void ab initio. The tribunal emphasized that an illegal assessment order cannot be legitimized through revisionary powers. The order was ultimately decided in favor of the assessee, quashing both the assessment order and the revisionary proceedings.

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