Search u/s 132 was conducted in the case of the assessee, a partnership firm engaged in manufacture of essential oils and perfumery, which claimed deduction u/s 80IC as its unit was located in Himachal Pradesh. The AO completed assessments u/s 153A r.w.s. 143(3) accepting the returned income without making any addition. The PCIT invoked revisional jurisdiction u/s 263 on the ground that the AO allowed deduction u/s 80IC without making necessary enquiries, holding that the assessee’s products were not covered in the eligible list under Schedule XIV and setting aside the assessment for fresh enquiry. On appeal, the Tribunal held that all the years under consideration were unabated assessment years and that no incriminating material was found during the search to justify any addition or disallowance. Following the ratio of PCIT v. Abhisar Buildwell (P.) Ltd. (2023) 149 taxmann.com 399 (SC), it was held that in absence of incriminating material, no addition or disallowance can be made in an assessment u/s 153A for completed/unabated years. Since the PCIT’s revision was not based on any such incriminating material and the AO had duly examined the assessee’s claim, the assessment could not be treated as erroneous or prejudicial to the interest of Revenue. Accordingly, the order u/s 263 was quashed.  (AY 2011-12 to 2018-19)  ( ITA Nos. 3713–3719/Mum/2025dated 27.10.2025.)