https://www.taxtmi.com/caselaws?id=757966 ITAT DELHI-AT allowed the assessee's appeal, holding the PCIT's revision under s.263 unsustainable for lack of jurisdiction. The Tribunal found the assessments under s.153A were completed after prior approval under s.153D, and a revisional authority must examine that approval record; absent a specific finding that the prior approval was vitiated or erroneous, the assessment cannot be held prejudicial to Revenue. As the Department did not challenge the approval before the HC or SC, the revision was invalid and the additions under s.40A(3) were overturned. en-us Fri, 30 Aug 2024 00:00:00 +0530 Sat, 20 Sep 2025 12:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757966 ITAT DELHI-AT allowed the assessee's appeal, holding the PCIT's revision under s.263 unsustainable for lack of jurisdiction. The Tribunal found the assessments under s.153A were completed after prior approval under s.153D, and a revisional authority must examine that approval record; absent a specific finding that the prior approval was vitiated or erroneous, the assessment cannot be held prejudicial to Revenue. As the Department did not challenge the approval before the HC or SC, the revision was invalid and the additions under s.40A(3) were overturned. Case-Laws Income Tax Fri, 30 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757966