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    <title>2024 (1) TMI 1076 - ITAT DELHI</title>
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    <description>Section 263 revision is unavailable where the Assessing Officer has made enquiries, considered the assessee&#039;s explanation on interest on enhanced compensation, and adopted one of two plausible views on taxability. The assessee had disclosed receipt linked to acquisition of agricultural land and claimed exemption under section 10(37), contending that interest under section 28 of the Land Acquisition Act, 1894 formed part of enhanced compensation. Because the assessment was made after enquiry on this debatable issue, it could not be treated as erroneous and prejudicial to the interests of the Revenue merely due to the Commissioner&#039;s different view. The revisionary order was therefore unsustainable.</description>
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      <description>Section 263 revision is unavailable where the Assessing Officer has made enquiries, considered the assessee&#039;s explanation on interest on enhanced compensation, and adopted one of two plausible views on taxability. The assessee had disclosed receipt linked to acquisition of agricultural land and claimed exemption under section 10(37), contending that interest under section 28 of the Land Acquisition Act, 1894 formed part of enhanced compensation. Because the assessment was made after enquiry on this debatable issue, it could not be treated as erroneous and prejudicial to the interests of the Revenue merely due to the Commissioner&#039;s different view. The revisionary order was therefore unsustainable.</description>
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