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ITAT set aside the Pr. CIT's revisional order under s.263, restoring the AO's reassessment order under s.147 r.w.s.144B. The Tribunal determined that the AO had arrived at a possible and plausible view regarding the taxpayer's eligibility for s.54B deduction after proper verification of agricultural use of the land. The Pr. CIT improperly substituted his own interpretation of ISRO satellite imagery and CCOST reports when the AO had already considered these alongside land revenue records, physical verification reports, and witness statements. The Tribunal held that revenue records evidencing agricultural use should be given precedence over satellite imagery, following Supreme Court precedent.
ITAT set aside the Pr. CIT's revisional order under s.263, restoring the AO's reassessment order under s.147 r.w.s.144B. The Tribunal determined that the AO had arrived at a possible and plausible view regarding the taxpayer's eligibility for s.54B deduction after proper verification of agricultural use of the land. The Pr. CIT improperly substituted his own interpretation of ISRO satellite imagery and CCOST reports when the AO had already considered these alongside land revenue records, physical verification reports, and witness statements. The Tribunal held that revenue records evidencing agricultural use should be given precedence over satellite imagery, following Supreme Court precedent.
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