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ITAT held that the revision under section 263 was unsustainable and the impugned revisionary order was set aside; the assessment framed by the AO was restored and the appeal allowed. The Tribunal found the assessee had furnished detailed explanations on the record and the AO had examined the identified aspects and taken one possible view; absence of elaborate discussion in the AO's order did not render it "erroneous and prejudicial to the interests of the revenue." Principal CIT failed to make independent findings demonstrating how non-examination of newly asserted issues rendered the assessment erroneous and prejudicial. Consequently, further inquiry or fresh determination under section 263 was not warranted.
ITAT held that the revision under section 263 was unsustainable and the impugned revisionary order was set aside; the assessment framed by the AO was restored and the appeal allowed. The Tribunal found the assessee had furnished detailed explanations on the record and the AO had examined the identified aspects and taken one possible view; absence of elaborate discussion in the AO's order did not render it "erroneous and prejudicial to the interests of the revenue." Principal CIT failed to make independent findings demonstrating how non-examination of newly asserted issues rendered the assessment erroneous and prejudicial. Consequently, further inquiry or fresh determination under section 263 was not warranted.
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