ITAT held that the revisionary orders passed by PCIT under s.263...

ITAT held that the revisionary orders passed by PCIT under s.263 were ultravires and unsustainable. The Tribunal found that the AO, in assessments framed under s.153A, did not make additions based on any incriminating material seized in the search, nor did the PCIT's s.263 order record reliance on such material. The PCIT's examination of the assessee's entitlement to deduction under s.80IC went beyond the scope of the s.153A assessment and thus outside the jurisdictional ambit of s.263. Consequently, the s.263 order was quashed as erroneous for lack of statutory mandate; the Tribunal did not adjudicate on the substantive merits of the s.80IC claim.

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