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ITAT allowed the assessee's appeal and quashed the revisional order passed u/s 263 by the PCIT. It held that the PCIT's action was prompted solely by an audit objection, which cannot by itself render the AO's order erroneous or prejudicial to the interests of Revenue. The AO had followed binding SC precedent on the taxability of interest received u/s 28 of the Land Acquisition Act, and the issue was at best debatable, with two possible views. In such circumstances, revisional jurisdiction u/s 263 could not be validly invoked. Consequently, the original assessment order of the AO was restored.
ITAT allowed the assessee's appeal and quashed the revisional order passed u/s 263 by the PCIT. It held that the PCIT's action was prompted solely by an audit objection, which cannot by itself render the AO's order erroneous or prejudicial to the interests of Revenue. The AO had followed binding SC precedent on the taxability of interest received u/s 28 of the Land Acquisition Act, and the issue was at best debatable, with two possible views. In such circumstances, revisional jurisdiction u/s 263 could not be validly invoked. Consequently, the original assessment order of the AO was restored.
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