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ITAT held that revision under s. 263 by the PCIT was unwarranted where the AO had conducted adequate inquiry and taken a permissible view regarding agricultural receipts and expenditures, which the AO treated as income from other sources rather than invoking ss. 68/69C r.w.s.115BBE. The AO verified ownership of agricultural land, corroborated sales evidence and bank statements, and applied consistent treatment in prior years; ad hoc disallowance of expenses did not render the assessment erroneous or prejudicial to Revenue. Accordingly, the PCIT's assumption of jurisdiction was quashed, the revision order set aside, the original assessment restored, and the assessee's appeal allowed.
ITAT held that revision under s. 263 by the PCIT was unwarranted where the AO had conducted adequate inquiry and taken a permissible view regarding agricultural receipts and expenditures, which the AO treated as income from other sources rather than invoking ss. 68/69C r.w.s.115BBE. The AO verified ownership of agricultural land, corroborated sales evidence and bank statements, and applied consistent treatment in prior years; ad hoc disallowance of expenses did not render the assessment erroneous or prejudicial to Revenue. Accordingly, the PCIT's assumption of jurisdiction was quashed, the revision order set aside, the original assessment restored, and the assessee's appeal allowed.
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