Anjali Jewellers v. PCIT (2021) 92 ITR 35 (Kol.)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Unabated assessment-No incriminating materials found during search-Revision was held to be not valid [[S. 143 (3), 153A]

Held that the assessment in respect of the relevant assessment year was not pending on the date of search. According to the second proviso to section 153A of the Act, the assessment for the year 2014-15 was an unabated assessment and the Assessing Officer while framing the assessment under section 153A of the Act taking note that there was no incriminating materials seized during search against the assessee qua the relevant assessment year. The assessment order passed by the Assessing Officer under section 153A / 143(3) was neither erroneous nor prejudicial to the interests of the Revenue. Revision order was quashed. (AY.2014-15)