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ITAT ruled in favor of the assessee, dismissing PCIT's revision petition under Section 263. The tribunal found that the assessing officer had conducted a comprehensive inquiry during original assessment proceedings, covering 25 detailed points including loan justifications. The key issues of unsecured interest-free loans and potential rental income were thoroughly examined. The tribunal emphasized that when the assessing officer adopts a legally permissible view, and two interpretations are possible, the order cannot be interfered with merely because another perspective exists. The court referenced precedents establishing that 263 proceedings are invalid when the initial assessment included proper enquiries and a plausible legal interpretation. Consequently, the PCIT's order was quashed and the assessee's appeal was allowed.
ITAT ruled in favor of the assessee, dismissing PCIT's revision petition under Section 263. The tribunal found that the assessing officer had conducted a comprehensive inquiry during original assessment proceedings, covering 25 detailed points including loan justifications. The key issues of unsecured interest-free loans and potential rental income were thoroughly examined. The tribunal emphasized that when the assessing officer adopts a legally permissible view, and two interpretations are possible, the order cannot be interfered with merely because another perspective exists. The court referenced precedents establishing that 263 proceedings are invalid when the initial assessment included proper enquiries and a plausible legal interpretation. Consequently, the PCIT's order was quashed and the assessee's appeal was allowed.
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