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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.
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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