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    <title>2023 (12) TMI 1292 - ITAT DELHI</title>
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    <description>The ITAT Delhi set aside the PCIT&#039;s revision order u/s 263 against a reassessment order u/s 147 concerning capital gains from agricultural land sale. The tribunal held that the AO had adequately investigated the matter by examining the sale deed and making specific enquiries about cash deposits in the savings account. Since the assessment was reopened for specific reasons which were duly examined by the AO, and no additions were made after accepting the assessee&#039;s explanations, the PCIT could not invoke section 263 powers. The tribunal ruled that for section 263 to apply, the AO&#039;s order must be both erroneous and prejudicial to revenue interests, which was not established here.</description>
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    <pubDate>Fri, 01 Dec 2023 00:00:00 +0530</pubDate>
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      <title>2023 (12) TMI 1292 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=312532</link>
      <description>The ITAT Delhi set aside the PCIT&#039;s revision order u/s 263 against a reassessment order u/s 147 concerning capital gains from agricultural land sale. The tribunal held that the AO had adequately investigated the matter by examining the sale deed and making specific enquiries about cash deposits in the savings account. Since the assessment was reopened for specific reasons which were duly examined by the AO, and no additions were made after accepting the assessee&#039;s explanations, the PCIT could not invoke section 263 powers. The tribunal ruled that for section 263 to apply, the AO&#039;s order must be both erroneous and prejudicial to revenue interests, which was not established here.</description>
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      <pubDate>Fri, 01 Dec 2023 00:00:00 +0530</pubDate>
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