Section 153D’s Institutional Check — How Prior Approval Limits PCIT’s Power to Invoke Section 263 in Search Assessments

The article analyses the impact of Section 153D introduction, which mandates prior institutional approval before invoking Section 263 for reassessments based on search-based income. This curbs arbitrary use of reassessment powers by tax authorities, adding procedural safeguards. The write-up underscores taxpayer protection, checks on discretion, and the evolving compliance framework under Indian Income Tax law.