Preliminary reassessment proceedings generally require statutory remedies unless jurisdiction is wholly absent or mandatory conditions are patently br...
Agricultural land classification requires cumulative factual indicators, while industrial-purpose land and absent agricultural use defeat reinvestment...
Composite residential flat exemption upheld where supplementary agreement merged adjoining units and additional evidence supported the taxpayer's inve...
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ITAT held that revision under section 263 was not justified because the AO had made adequate enquiry on cash sales, cash deposits, opening stock and purchases, and the assessee had furnished replies and records during assessment. The Tribunal found no lack of enquiry and held that the Principal Commissioner could not invoke revision merely to substitute a different view on the same material. Applying the principle that section 263 requires both error and prejudice to revenue, and that revision is unavailable where two plausible views exist, the Tribunal quashed the revisionary orders and allowed all three appeals.
ITAT held that revision under section 263 was not justified because the AO had made adequate enquiry on cash sales, cash deposits, opening stock and purchases, and the assessee had furnished replies and records during assessment. The Tribunal found no lack of enquiry and held that the Principal Commissioner could not invoke revision merely to substitute a different view on the same material. Applying the principle that section 263 requires both error and prejudice to revenue, and that revision is unavailable where two plausible views exist, the Tribunal quashed the revisionary orders and allowed all three appeals.
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