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ITAT held that income declared during survey proceedings was properly assessed as business income at normal tax rates rather than under s.115BBE. The assessee's voluntary disclosure during survey itself, before assessment completion, distinguished this case. Following Dharti Estate precedent, since AO had conducted due diligence and consciously treated the undisclosed amounts as business income after verifying evidence and allowing related partner payments, Pr.CIT's revision under s.263 was invalid. ITAT emphasized that s.263 powers are limited to examining if order is erroneous/prejudicial to revenue, not re-adjudicating assessment merits. Revision proceedings quashed in assessee's favor as AO's treatment was neither erroneous nor prejudicial to revenue interests.
ITAT held that income declared during survey proceedings was properly assessed as business income at normal tax rates rather than under s.115BBE. The assessee's voluntary disclosure during survey itself, before assessment completion, distinguished this case. Following Dharti Estate precedent, since AO had conducted due diligence and consciously treated the undisclosed amounts as business income after verifying evidence and allowing related partner payments, Pr.CIT's revision under s.263 was invalid. ITAT emphasized that s.263 powers are limited to examining if order is erroneous/prejudicial to revenue, not re-adjudicating assessment merits. Revision proceedings quashed in assessee's favor as AO's treatment was neither erroneous nor prejudicial to revenue interests.
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