https://www.taxtmi.com/caselaws?id=780941 ITAT, Pune held the Principal Commissioner's revision under s.263 unjustified and set aside the revision order. The Tribunal found the AO plausibly treated excess cash and stock found in survey as business income after inquiries, so the twin conditions for s.263 (order erroneous and prejudicial to Revenue) were not satisfied despite potential prejudice. Invocation of s.115BBE on such amounts was not mandatory. The revision was vacated and the assessee's grounds were allowed, with reliance on settled SC/HC precedents that when two views are possible the assessee-favouring view prevails. en-us Tue, 04 Nov 2025 00:00:00 +0530 Mon, 22 Jun 2026 14:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780941 ITAT, Pune held the Principal Commissioner's revision under s.263 unjustified and set aside the revision order. The Tribunal found the AO plausibly treated excess cash and stock found in survey as business income after inquiries, so the twin conditions for s.263 (order erroneous and prejudicial to Revenue) were not satisfied despite potential prejudice. Invocation of s.115BBE on such amounts was not mandatory. The revision was vacated and the assessee's grounds were allowed, with reliance on settled SC/HC precedents that when two views are possible the assessee-favouring view prevails. Case-Laws Income Tax Tue, 04 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780941