https://www.taxtmi.com/caselaws?id=768732 ITAT Hyderabad allowed the assessee's appeal against PCIT's revision order under section 263 regarding unexplained investment in land purchase. The tribunal held that the assessment order under section 153A was not erroneous or prejudicial to revenue interests. The seized document relied upon by PCIT contained only cheque payment details without any incriminating material regarding cash on-money payments. Sworn statements showed internal contradictions and were unreliable for determining payment periods. The AO had adopted a plausible view based on available evidence, concluding on-money payments of Rs. 32.66 crores occurred during AY 2020-21/2021-22, not AY 2017-18 and 2018-19 as claimed by PCIT. The revision order was unsustainable as adopting one plausible view doesn't render assessment erroneous under section 263. en-us Wed, 09 Apr 2025 00:00:00 +0530 Sat, 12 Apr 2025 08:39:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768732 ITAT Hyderabad allowed the assessee's appeal against PCIT's revision order under section 263 regarding unexplained investment in land purchase. The tribunal held that the assessment order under section 153A was not erroneous or prejudicial to revenue interests. The seized document relied upon by PCIT contained only cheque payment details without any incriminating material regarding cash on-money payments. Sworn statements showed internal contradictions and were unreliable for determining payment periods. The AO had adopted a plausible view based on available evidence, concluding on-money payments of Rs. 32.66 crores occurred during AY 2020-21/2021-22, not AY 2017-18 and 2018-19 as claimed by PCIT. The revision order was unsustainable as adopting one plausible view doesn't render assessment erroneous under section 263. Case-Laws Income Tax Wed, 09 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768732