https://www.taxtmi.com/caselaws?id=763964 ITAT Jodhpur allowed the assessee's appeal against CIT's revision order u/s 263. The CIT had alleged that the AO erroneously allowed excess deduction u/s 57, resulting in under-assessment of income. The tribunal held that since the AO had conducted detailed enquiry and made elaborate submissions before allowing the deduction, the CIT could not form a different view on the same issue. Citing precedent, the tribunal ruled that the newly inserted Explanation 2(a) to Section 263 does not grant unfettered powers to the Commissioner to revise orders based on subjective opinion. The assessment order was neither erroneous nor prejudicial to revenue interests. en-us Mon, 23 Dec 2024 00:00:00 +0530 Tue, 31 Dec 2024 16:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763964 ITAT Jodhpur allowed the assessee's appeal against CIT's revision order u/s 263. The CIT had alleged that the AO erroneously allowed excess deduction u/s 57, resulting in under-assessment of income. The tribunal held that since the AO had conducted detailed enquiry and made elaborate submissions before allowing the deduction, the CIT could not form a different view on the same issue. Citing precedent, the tribunal ruled that the newly inserted Explanation 2(a) to Section 263 does not grant unfettered powers to the Commissioner to revise orders based on subjective opinion. The assessment order was neither erroneous nor prejudicial to revenue interests. Case-Laws Income Tax Mon, 23 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763964