Difference of opinion cannot justify Section 263 revision if AO taken Plausible View

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...