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ITAT partially allowed the assessee's appeal against PCIT's revision order under Section 263. The tribunal found that while PCIT correctly identified AO's failure to examine applicability of Section 43CA regarding differences between stamp duty values and agreement values for property transactions, the revision was sustainable only for two transactions where differences exceeded tolerance bands. For five transactions, no Section 43CA addition was warranted, making the assessment order non-erroneous. ITAT rejected assessee's contention that Section 43CA should be applied by aggregating all transactions, clarifying that each transaction must be examined individually. The tribunal upheld PCIT's order regarding two transactions where AO failed proper inquiry despite apparent discrepancies, but set aside revision for remaining five transactions where assessment was not erroneous.
ITAT partially allowed the assessee's appeal against PCIT's revision order under Section 263. The tribunal found that while PCIT correctly identified AO's failure to examine applicability of Section 43CA regarding differences between stamp duty values and agreement values for property transactions, the revision was sustainable only for two transactions where differences exceeded tolerance bands. For five transactions, no Section 43CA addition was warranted, making the assessment order non-erroneous. ITAT rejected assessee's contention that Section 43CA should be applied by aggregating all transactions, clarifying that each transaction must be examined individually. The tribunal upheld PCIT's order regarding two transactions where AO failed proper inquiry despite apparent discrepancies, but set aside revision for remaining five transactions where assessment was not erroneous.
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