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ITAT ruled against revision under s.263, finding the original assessment order valid and not prejudicial to revenue interests. The disputed cash deposit of Rs.4.5 lakh, initially part of a land transaction that was subsequently cancelled, resulted in nil cash flow impact. The AO had properly followed assessment procedures under s.143(3) r.w.s 147/148, issuing required notices and examining bank statements, agricultural income declarations, and supporting documentation. The tribunal determined the assessment of Rs.6,710 plus Rs.7,80,000 agricultural income was reasonable, with due verification completed. The PCIT's attempt to invoke s.263 was rejected as the original assessment demonstrated proper examination of facts and application of law.
ITAT ruled against revision under s.263, finding the original assessment order valid and not prejudicial to revenue interests. The disputed cash deposit of Rs.4.5 lakh, initially part of a land transaction that was subsequently cancelled, resulted in nil cash flow impact. The AO had properly followed assessment procedures under s.143(3) r.w.s 147/148, issuing required notices and examining bank statements, agricultural income declarations, and supporting documentation. The tribunal determined the assessment of Rs.6,710 plus Rs.7,80,000 agricultural income was reasonable, with due verification completed. The PCIT's attempt to invoke s.263 was rejected as the original assessment demonstrated proper examination of facts and application of law.
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