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ITAT quashed PCIT's revision order u/s 263 challenging validity of reassessment proceedings u/s 153A regarding computation of total income claiming interest u/s 24B. Tribunal held that Explanation 2 invoked by PCIT had no application as all relevant documents were filed by assessee during reassessment proceedings, which AO verified before finalizing assessment allowing interest claim u/s 24B. ITAT noted AO had previously allowed similar interest claim in AY 2012-13, establishing continuing cause of action that cannot be disturbed without different factual findings. Tribunal found PCIT's order reflected non-application of mind since AO had conducted adequate inquiries and examination of assessee's claims during both original and reassessment proceedings u/s 153A, taking plausible view not prejudicial to Revenue interests. Appeal allowed.
ITAT quashed PCIT's revision order u/s 263 challenging validity of reassessment proceedings u/s 153A regarding computation of total income claiming interest u/s 24B. Tribunal held that Explanation 2 invoked by PCIT had no application as all relevant documents were filed by assessee during reassessment proceedings, which AO verified before finalizing assessment allowing interest claim u/s 24B. ITAT noted AO had previously allowed similar interest claim in AY 2012-13, establishing continuing cause of action that cannot be disturbed without different factual findings. Tribunal found PCIT's order reflected non-application of mind since AO had conducted adequate inquiries and examination of assessee's claims during both original and reassessment proceedings u/s 153A, taking plausible view not prejudicial to Revenue interests. Appeal allowed.
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