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ITAT set aside PCIT's revision order under section 263 regarding cooperative society's deduction claim under section 80P(2)(a) and 80P(2)(d) for interest income. The Tribunal held that while AO's order allowing deduction may be prejudicial to revenue interest, it was not erroneous since AO conducted proper inquiry and took plausible view after examining assessee's responses. Following coordinate bench precedent in Talegaon Nagari Sahakari Patsanstha Limited, interest income from deposits with banks qualified for deduction. ITAT emphasized twin conditions for section 263 jurisdiction - order must be both erroneous and prejudicial to revenue. Since AO's decision was reasoned and based on adequate examination, PCIT lacked jurisdiction to revise. Appeal allowed, revision order quashed.
ITAT set aside PCIT's revision order under section 263 regarding cooperative society's deduction claim under section 80P(2)(a) and 80P(2)(d) for interest income. The Tribunal held that while AO's order allowing deduction may be prejudicial to revenue interest, it was not erroneous since AO conducted proper inquiry and took plausible view after examining assessee's responses. Following coordinate bench precedent in Talegaon Nagari Sahakari Patsanstha Limited, interest income from deposits with banks qualified for deduction. ITAT emphasized twin conditions for section 263 jurisdiction - order must be both erroneous and prejudicial to revenue. Since AO's decision was reasoned and based on adequate examination, PCIT lacked jurisdiction to revise. Appeal allowed, revision order quashed.
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