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ITAT allowed the assessee's appeal against exercise of revisionary jurisdiction under s.263 by the PCIT, holding that the AO had in fact made inquiries into the assessee's claim of substantial agricultural income. Notices under s.142(1), a show-cause notice and filed responses with documents demonstrated that the AO considered and accepted a possible view; any alleged inadequacy of inquiry did not equate to "no inquiry." Explanation 2 to s.263 does not permit the PCIT to reappraise evidence and substitute his opinion where inquiries were made and a plausible conclusion recorded. The PCIT's assumption of jurisdiction was therefore invalid and the revision order was set aside.
ITAT allowed the assessee's appeal against exercise of revisionary jurisdiction under s.263 by the PCIT, holding that the AO had in fact made inquiries into the assessee's claim of substantial agricultural income. Notices under s.142(1), a show-cause notice and filed responses with documents demonstrated that the AO considered and accepted a possible view; any alleged inadequacy of inquiry did not equate to "no inquiry." Explanation 2 to s.263 does not permit the PCIT to reappraise evidence and substitute his opinion where inquiries were made and a plausible conclusion recorded. The PCIT's assumption of jurisdiction was therefore invalid and the revision order was set aside.
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