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ITAT ruled that the PCIT's revision order under Section 263 was unsustainable. The Tribunal found no incriminating material in the seized documents to support claims of undisclosed on-money payments during Assessment Years 2017-18 and 2018-19. Contradictory statements from witnesses and lack of documentary evidence undermined the revenue's position. The Assessing Officer had adopted a plausible view regarding on-money payments, which were determined to be made during Assessment Years 2020-21 and 2021-22. Consequently, the Tribunal held that adopting an alternative interpretation does not render the original assessment order erroneous or prejudicial to revenue interests. The assessee's appeal was allowed, effectively setting aside the revision order.
ITAT ruled that the PCIT's revision order under Section 263 was unsustainable. The Tribunal found no incriminating material in the seized documents to support claims of undisclosed on-money payments during Assessment Years 2017-18 and 2018-19. Contradictory statements from witnesses and lack of documentary evidence undermined the revenue's position. The Assessing Officer had adopted a plausible view regarding on-money payments, which were determined to be made during Assessment Years 2020-21 and 2021-22. Consequently, the Tribunal held that adopting an alternative interpretation does not render the original assessment order erroneous or prejudicial to revenue interests. The assessee's appeal was allowed, effectively setting aside the revision order.
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