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Difference of opinion cannot justify Section 263 revision if AO taken Plausible View
Case Law Details
- Case Name
- Dr. Pratap Pandharinath Patil Vs PCIT (ITAT Pune)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
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Dr. Pratap Pandharinath Patil Vs PCIT (ITAT Pune)
Assessee, Dr. Pratap Pandharinath Patil, filed appeal against the revisionary order u/s 263 passed by PCIT on 05.02.2025 setting aside the assessment framed u/s 143(3) r.w.s. 144B dated 12.09.2022. AO had examined agricultural income of Rs.53.02 lakh declared by Assessee, out of which receipts of Rs.38.46 lakh & expenditure of Rs.4.36 lakh were not substantiated. AO treated them as “Income from Other Sources” instead of invoking ss. 68 & 69C r.w.s. 115BBE.
PCIT, in revision, held that AO’s treatment was erroneous & prejudicial...
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