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ITAT allowed the assessee's appeal, holding that the Principal Commissioner's revisional order under section 263 was unsustainable. The tribunal found that the Assessing Officer's decision regarding taxability of interest component on land acquisition compensation under section 28 of the Land Acquisition Act, 1894 was based on Supreme Court precedent in Ghanshyam HUF. The PCIT's action was prompted solely by audit objection, which cannot establish that the original assessment order was erroneous or prejudicial to revenue interests. Since the matter involved debatable legal issues with two possible views, and the AO adopted one reasonable interpretation supported by judicial precedent, the PCIT lacked jurisdiction to invoke revisional powers under section 263.
ITAT allowed the assessee's appeal, holding that the Principal Commissioner's revisional order under section 263 was unsustainable. The tribunal found that the Assessing Officer's decision regarding taxability of interest component on land acquisition compensation under section 28 of the Land Acquisition Act, 1894 was based on Supreme Court precedent in Ghanshyam HUF. The PCIT's action was prompted solely by audit objection, which cannot establish that the original assessment order was erroneous or prejudicial to revenue interests. Since the matter involved debatable legal issues with two possible views, and the AO adopted one reasonable interpretation supported by judicial precedent, the PCIT lacked jurisdiction to invoke revisional powers under section 263.
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