https://www.taxtmi.com/caselaws?id=426138 ITAT held that the PCIT's revision under s.263 was unsustainable and upheld the AO's assessment in favour of the assessee. The AO, after considering survey statements, a surrender letter and the return, assessed the receipts as business income and did not invoke deeming provisions or s.115BBE; ITAT found the PCIT failed to record specific findings showing applicability of s.68/69/69A/69B/69C and could not treat survey disclosures as automatically attracting deeming provisions. Accordingly the AO's order was not erroneous or prejudicial to revenue. en-us Thu, 04 Aug 2022 00:00:00 +0530 Thu, 06 Nov 2025 14:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=426138 ITAT held that the PCIT's revision under s.263 was unsustainable and upheld the AO's assessment in favour of the assessee. The AO, after considering survey statements, a surrender letter and the return, assessed the receipts as business income and did not invoke deeming provisions or s.115BBE; ITAT found the PCIT failed to record specific findings showing applicability of s.68/69/69A/69B/69C and could not treat survey disclosures as automatically attracting deeming provisions. Accordingly the AO's order was not erroneous or prejudicial to revenue. Case-Laws Income Tax Thu, 04 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=426138