Revision under section 263 was quashed because the revising officer failed to record material or a basis to show the AO's assessment was erroneous and prejudicial to revenue; the tribunal found the AO had reasonably treated six funds as equity-oriented (entitling them to taxation under Section 112A) and that the assessee had furnished fund documentation and holding-period evidence. The tribunal also upheld the Assessing Officer's accepted Annual Letting Values for multiple properties where no contrary basis was shown by the reviser, and held penalty initiation lacked requisite material; quash subject to AO verifying purchase cost of the SBI Gold Fund.
Revision under section 263 was quashed because the revising officer failed to record material or a basis to show the AO's assessment was erroneous and prejudicial to revenue; the tribunal found the AO had reasonably treated six funds as equity-oriented (entitling them to taxation under Section 112A) and that the assessee had furnished fund documentation and holding-period evidence. The tribunal also upheld the Assessing Officer's accepted Annual Letting Values for multiple properties where no contrary basis was shown by the reviser, and held penalty initiation lacked requisite material; quash subject to AO verifying purchase cost of the SBI Gold Fund.
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