https://www.taxtmi.com/caselaws?id=768882 ITAT Hyderabad quashed PCIT's revision order u/s 263 of Income Tax Act. The assessee made cash payments for agricultural land purchases not offered for taxation in AY 2019-20. ITAT held that AO's satisfaction note u/s 153C was invalid as no direct correlation existed between incriminating material found during search and the assessment year. Following Supreme Court precedent in Sinhgad Technical Education Society, ITAT ruled that without proper satisfaction note linking incriminating material to specific assessment year, proceedings u/s 153C are void ab initio. Since the underlying assessment order was illegal, PCIT's revisionary jurisdiction u/s 263 was also invalid. Order decided in favor of assessee. en-us Wed, 09 Apr 2025 00:00:00 +0530 Tue, 15 Apr 2025 08:35:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768882 ITAT Hyderabad quashed PCIT's revision order u/s 263 of Income Tax Act. The assessee made cash payments for agricultural land purchases not offered for taxation in AY 2019-20. ITAT held that AO's satisfaction note u/s 153C was invalid as no direct correlation existed between incriminating material found during search and the assessment year. Following Supreme Court precedent in Sinhgad Technical Education Society, ITAT ruled that without proper satisfaction note linking incriminating material to specific assessment year, proceedings u/s 153C are void ab initio. Since the underlying assessment order was illegal, PCIT's revisionary jurisdiction u/s 263 was also invalid. Order decided in favor of assessee. Case-Laws Income Tax Wed, 09 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768882