https://www.taxtmi.com/caselaws?id=456752 The ITAT Surat quashed the PCIT's revision order u/s 263 challenging the AO's allowance of deduction u/s 54B. The PCIT contended the AO failed to verify if the assessee used agricultural land for two years preceding transfer and noted no agricultural income disclosure. The ITAT held that the AO had conducted proper inquiry by seeking details and documents from the assessee, who provided comprehensive responses. The tribunal distinguished between lack of inquiry versus inadequate inquiry, ruling that mere difference of opinion cannot justify revision orders. Since the AO applied his mind after examining relevant materials, the assessment order was neither erroneous nor prejudicial to revenue interests. The assessee's appeal was allowed. en-us Mon, 15 May 2023 00:00:00 +0530 Wed, 25 Feb 2026 17:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456752 The ITAT Surat quashed the PCIT's revision order u/s 263 challenging the AO's allowance of deduction u/s 54B. The PCIT contended the AO failed to verify if the assessee used agricultural land for two years preceding transfer and noted no agricultural income disclosure. The ITAT held that the AO had conducted proper inquiry by seeking details and documents from the assessee, who provided comprehensive responses. The tribunal distinguished between lack of inquiry versus inadequate inquiry, ruling that mere difference of opinion cannot justify revision orders. Since the AO applied his mind after examining relevant materials, the assessment order was neither erroneous nor prejudicial to revenue interests. The assessee's appeal was allowed. Case-Laws Income Tax Mon, 15 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456752