No Section 263 Revision When Two Views Possible on Section 28 Interest on Enhanced Compensation

Mange Ram Vs PCIT (ITAT Delhi) This appeal for Assessment Year 2017–18 arose against the order dated 04.12.2023 passed by the Principal Commissioner of Income Tax (PCIT), Faridabad under Section 147 read with Section 144 of the Income-tax Act, 1961. The sole substantive issue was the correctness of the action of the lower authorities in assessing the interest component received on land acquisition compensation under Section 28 of the Land Acquisition Act, 1894 as income from “other sources” by invoking Sections 57(iv), 56(1)(a) and 145A(b) of the Act. The Revenue relied upon the decision...