ITAT quashed order under section 263 as CIT could not pinpoint any seized material relating to the issues on which revisionary directions is exercised
Hon’ble Delhi ITAT in the case of Tarun Radhakrishin Tahiliani v. PCIT (ITA No. 2323/DEL/2024, dated 28.03.2025) has quashed the order under Section 263 of the Income Tax Act, holding that an “unabated” assessment order passed under Section 153A cannot be termed as erroneous so far as prejudicial to the interest of the revenue when the PCIT/department failed to pin-point any seized material relating to the issues on which revisionary directions were issued. Its an ideal example of the quote “What cannot be done directly cannot be done indirectly”.
The Copy Of the order is as under:
