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The ITAT addressed a case involving revision u/s 263 where the main allegation was the non-disclosure of agricultural income affecting the deduction u/s 54B. The tribunal clarified that an AO's order can be considered erroneous if based on incorrect fact, law, or lacks investigation. The phrase "prejudicial to the interest of the revenue" must align with an erroneous order. Loss due to a lawful decision or a difference in opinion isn't necessarily prejudicial. In this case, the AO's assessment was meticulous and lawful, not prejudicing revenue. The PCIT's critique lacked inquiry and was deemed erroneous and prejudicial. The AO's detailed investigation and lawful order led to the quashing of the PCIT's revision. The appeal was allowed.
The ITAT addressed a case involving revision u/s 263 where the main allegation was the non-disclosure of agricultural income affecting the deduction u/s 54B. The tribunal clarified that an AO's order can be considered erroneous if based on incorrect fact, law, or lacks investigation. The phrase "prejudicial to the interest of the revenue" must align with an erroneous order. Loss due to a lawful decision or a difference in opinion isn't necessarily prejudicial. In this case, the AO's assessment was meticulous and lawful, not prejudicing revenue. The PCIT's critique lacked inquiry and was deemed erroneous and prejudicial. The AO's detailed investigation and lawful order led to the quashing of the PCIT's revision. The appeal was allowed.
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