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The ITAT held that the AO committed an error prejudicial to the Revenue's interest by failing to tax the notional annual letting value of the assessee company's unsold building inventories under 'income from house property'. Relying on judicial precedents, the ITAT ruled that unsold building inventories attract taxation on their notional rental income, which the AO erroneously omitted despite reopening assessment for this specific purpose. Consequently, the twin conditions for revision u/s 263 were satisfied, and the matter was decided against the assessee.
The ITAT held that the AO committed an error prejudicial to the Revenue's interest by failing to tax the notional annual letting value of the assessee company's unsold building inventories under 'income from house property'. Relying on judicial precedents, the ITAT ruled that unsold building inventories attract taxation on their notional rental income, which the AO erroneously omitted despite reopening assessment for this specific purpose. Consequently, the twin conditions for revision u/s 263 were satisfied, and the matter was decided against the assessee.
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