https://www.taxtmi.com/caselaws?id=768348 ITAT Chennai quashed PCIT's revision order u/s 263 challenging search assessment u/s 153A. The assessee had offered income including taxes on anonymous donations u/s 115BBC and corpus donations u/s 11. ITAT held twin conditions of Section 263 were not satisfied as AO conducted proper inquiry during search proceedings, took plausible view, and no revenue prejudice existed since assessee paid applicable taxes. AO had examined complete details, recorded seized materials and statements, and verified facts before completing assessment. Revenue could not invoke Explanation 2(d) of Section 263 citing subsequent HC judgment in MAC Public Charitable Trust case as it didn't exist when search assessment was passed. Appeal allowed. en-us Tue, 15 Oct 2024 00:00:00 +0530 Thu, 03 Apr 2025 17:52:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768348 ITAT Chennai quashed PCIT's revision order u/s 263 challenging search assessment u/s 153A. The assessee had offered income including taxes on anonymous donations u/s 115BBC and corpus donations u/s 11. ITAT held twin conditions of Section 263 were not satisfied as AO conducted proper inquiry during search proceedings, took plausible view, and no revenue prejudice existed since assessee paid applicable taxes. AO had examined complete details, recorded seized materials and statements, and verified facts before completing assessment. Revenue could not invoke Explanation 2(d) of Section 263 citing subsequent HC judgment in MAC Public Charitable Trust case as it didn't exist when search assessment was passed. Appeal allowed. Case-Laws Income Tax Tue, 15 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768348