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ITAT overturned PCIT's revision order under s.263 regarding treatment of income surrendered during survey. The tribunal found AO had conducted proper inquiry into excess cosmetics stock discovered during survey. AO accepted assessee's explanation that undisclosed income arose from regular business transactions, not unexplained investments. Assessee demonstrated excess stock valued at cost was Rs.17 lakhs, not Rs.50 lakhs claimed. Since AO took a legally plausible view after adequate verification that s.115BBE was inapplicable, and no evidence existed of income from sources besides cosmetics business, PCIT's revision jurisdiction was unjustified. The original assessment order was neither erroneous nor prejudicial to revenue interests. Appeal allowed in assessee's favor.
ITAT overturned PCIT's revision order under s.263 regarding treatment of income surrendered during survey. The tribunal found AO had conducted proper inquiry into excess cosmetics stock discovered during survey. AO accepted assessee's explanation that undisclosed income arose from regular business transactions, not unexplained investments. Assessee demonstrated excess stock valued at cost was Rs.17 lakhs, not Rs.50 lakhs claimed. Since AO took a legally plausible view after adequate verification that s.115BBE was inapplicable, and no evidence existed of income from sources besides cosmetics business, PCIT's revision jurisdiction was unjustified. The original assessment order was neither erroneous nor prejudicial to revenue interests. Appeal allowed in assessee's favor.
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