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Case involved revision u/s 263 by the Commissioner of Income Tax (CIT) setting aside assessment order regarding rent recovered from specified persons and treatment of foreign contribution as income. Held: Case selected for limited scrutiny on two points - income/property lent to specified persons and land/building made available for use. Assessing Officer (AO) made adequate inquiry, accepted return. CIT cannot impose views when plausible view taken by AO. Every revenue loss due to AO's order cannot be treated as prejudicial to revenue interest. On foreign contribution, case not selected for scrutiny on that point. AO had no jurisdiction, cannot extend limited scrutiny scope. When two possible views and AO took one, CIT cannot treat it as erroneous unless AO's view unsustainable. AO's view not erroneous or prejudicial to revenue. Decided in favor of assessee.
Case involved revision u/s 263 by the Commissioner of Income Tax (CIT) setting aside assessment order regarding rent recovered from specified persons and treatment of foreign contribution as income. Held: Case selected for limited scrutiny on two points - income/property lent to specified persons and land/building made available for use. Assessing Officer (AO) made adequate inquiry, accepted return. CIT cannot impose views when plausible view taken by AO. Every revenue loss due to AO's order cannot be treated as prejudicial to revenue interest. On foreign contribution, case not selected for scrutiny on that point. AO had no jurisdiction, cannot extend limited scrutiny scope. When two possible views and AO took one, CIT cannot treat it as erroneous unless AO's view unsustainable. AO's view not erroneous or prejudicial to revenue. Decided in favor of assessee.
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