Section 263 Invalid Where AO Took Plausible View on Farm Income: ITAT Delhi

Prahlad Singh Vs PCIT (ITAT Delhi) PCIT Cannot Invoke Section 263 to Force Tax u/s 69A Where AO Took a Plausible View on Agricultural Income – ITAT Delhi The Delhi Bench of the ITAT quashed the revision order passed under section 263 for AY 2020-21, holding that the PCIT had wrongly assumed jurisdiction by treating the assessment as erroneous and prejudicial to the interests of revenue. The assessee had declared agricultural income, which the AO—after examining land records, Form-J sale proceeds, purchase bills, and government-issued landholding documents—treated as income from other sou...