आदेश / O R D E R

PER PRABHASH SHANKAR [A.M.] :-

The above captioned appeals are preferred by the assessee against the orders passed by the Principal Commissioner of Income-tax (Central), Mumbai–1 [hereinafter referred to as “PCIT(C)”] pertaining to Revision orders passed u/s. 263 of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for Assessment Years[A.Y.] 2014-15, 2015-16 & 2018-19. All the above stated appeals are interrelated involving identical grounds of appeal and also these appeals have been heard together, therefore, they are being adjudicated in this composite order for the sake of brevity. We take up the appeals in the case of ITA 8780/MUM/2025 (A.Y.2018-19) in the case of Bondwell Corporate Advisor Private Limited first, which is taken as ‘Lead Case’ and the decision herein would apply mutatis mutandis on identical issues.

2. The common grounds of all the appeals are as under:

1. That the notice issued under Section 263 of the Income Tax Act, 1961 ("the Act") and the order passed by the Principal Commissioner of Income Tax (Central), Mumbai are bad in law, without jurisdiction, barred by limitation, and not in accordance with the provisions of the Act.

2. That the assumption of jurisdiction under Section 263 of the Act is vitiated, as the notice issued under Section 153C of the Act and consequential assessment order passed is not in accordance with law having been issued without adherence to the mandatory preconditions stipulated under the Act rendering the entire revision proceedings void ab initio.

3. That on the facts and in the circumstances of the case, the assumption of jurisdiction under Section 263 of the Act is bad in law and without jurisdiction, as the assessment sought to be revised is founded on proceedings initiated without recording the mandatory satisfaction that the alleged seized material had any bearing on the determination of the assessee's income, thereby rendering the impugned proceedings void ab initio and not amenable to revision under Section 263 of the Act.

4. That the learned Principal Commissioner of Income Tax has erred in assuming jurisdiction under Section 263 of the Act without setting aside or invalidating the statutory approval under Section 153D of the Act forming the foundation of the assessment, rendering the impugned revision proceedings without jurisdiction and bad in law.

5. That the PCIT, Mumbai has erred in invoking Explanation 2 to section 263 of the Act by holding the assessment order to be erroneous and prejudicial to the interests of the Revenue, despite the fact that the Assessing Officer had completed the assessment after due and comprehensive enquiry and verification.

6. That the PCIT, Mumbai has failed to appreciate that the issues raised in the show cause notice, at best, pertain to the adequacy of enquiry and not lack of enquiry, which is not a valid ground for invoking jurisdiction under Section 263 of the Act.

7. The PCIT, Mumbai erred in setting aside the assessment order passed under Section 153C for making fresh assessment without assigning any defects or inconsistency in the assessment order, thus invoking revisionary powers u/s 263 of the Act merely for make roving and fishing query is beyond the jurisdiction and unjustified.

8. That PCIT, Mumbai failed to appreciate that assessment order was passed in the group cases which were centralised, after analysis of all the incriminating seized material (in the case of Alankit Group), statement recorded and after mandatory approval u/s 153D of the Act from Addl CIT and therefore, to hold such an order as erroneous and prejudicial to the interest of the revenue is unjustified and bad in law.

9. The PCIT, Mumbai in the impugned order as failed to point out any specific defect or escapement of income or any particular issue or document which had remained to be examine, therefore, merely invoking Explanation 2 to sec. 263 in fact of the case is not justified.

10. That the impugned order passed under Section