Section 263 revision fails for unabated 153A assessment where no specific seized material supports the proposed additions.

For an unabated assessment under section 153A, additions must be grounded in specific seized material; absent such material, a revision under section 263 cannot be sustained merely on proposed issues such as deemed dividend, commission payment or cash transactions. The assessment order was therefore not shown to be both erroneous and prejudicial to the interests of the revenue on the facts described, and the revision was set aside in favour of the assessee.

---

---

Issues: Whether the revision under section 263 of the Income-tax Act, 1961, could be sustained for an unabated assessment under section 153A in the absence of specific seized material supporting the proposed additions.

Analysis: The search took place after the relevant assessment year had already attained unabated status, so any addition in section 153A proceedings had to rest on seized material. The proposed revision related to deemed dividend, commission payment, and cash transactions, but no specific seized material was identified to support those issues. In these circumstances, the assessment order could not be treated as both erroneous and prejudicial to the interests of the revenue so as to justify revision under section 263.

Conclusion: The revision under section 263 was not sustainable and was set aside, in favour of the assessee.

---