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ITAT held that the AO conducted proper inquiry into agricultural income claims, thoroughly examining documentary evidence supporting the assessee's declaration. The Ld. PCIT's attempt to revise the assessment order under Section 263 was deemed inappropriate, as the AO had diligently verified the agricultural income, satisfied with the explanations and materials on record. The tribunal emphasized that revisional powers are limited when the AO has conducted comprehensive inquiries and reached plausible legal conclusions. Consequently, the assessee's appeal was allowed, rejecting the revisional proceedings initiated by the PCIT based on mere apprehensions and without substantive grounds for challenging the original assessment order.
ITAT held that the AO conducted proper inquiry into agricultural income claims, thoroughly examining documentary evidence supporting the assessee's declaration. The Ld. PCIT's attempt to revise the assessment order under Section 263 was deemed inappropriate, as the AO had diligently verified the agricultural income, satisfied with the explanations and materials on record. The tribunal emphasized that revisional powers are limited when the AO has conducted comprehensive inquiries and reached plausible legal conclusions. Consequently, the assessee's appeal was allowed, rejecting the revisional proceedings initiated by the PCIT based on mere apprehensions and without substantive grounds for challenging the original assessment order.
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