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Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
ITAT allowed assessee's appeal against revision proceedings under s.263 concerning 100% deduction claimed under s.80IC. PCIT's revision order was set aside as it failed to demonstrate how AO's inquiry was inadequate or unreasonable. AO had conducted proper verification by issuing notices, examining submissions and documentation before allowing the deduction claim. The assessment order's brevity alone does not justify revision jurisdiction when assessment records show due application of mind. ITAT held that AO's conclusion allowing 100% deduction was a plausible view that a prudent officer could take, and mere desire for re-verification cannot render the order erroneous or prejudicial to Revenue's interests under s.263.
ITAT allowed assessee's appeal against revision proceedings under s.263 concerning 100% deduction claimed under s.80IC. PCIT's revision order was set aside as it failed to demonstrate how AO's inquiry was inadequate or unreasonable. AO had conducted proper verification by issuing notices, examining submissions and documentation before allowing the deduction claim. The assessment order's brevity alone does not justify revision jurisdiction when assessment records show due application of mind. ITAT held that AO's conclusion allowing 100% deduction was a plausible view that a prudent officer could take, and mere desire for re-verification cannot render the order erroneous or prejudicial to Revenue's interests under s.263.
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