Section 263 Revision Quashed as Safe Harbour Rule of 10% Held Retrospective: ITAT Raipur

Anil Agrawal Vs ACIT (ITAT Raipur) The appeal before the ITAT Raipur arose from an order passed under Section 263 of the Income Tax Act, 1961 by the Principal Commissioner of Income Tax (Central), Bhopal for Assessment Year 2018-19. The assessee challenged the validity of the revision order on the ground that the conditions under Explanation 2 to Section 263 were not satisfied. The assessee had originally filed a return declaring income of ₹7,95,750. He purchased land for ₹18,00,000, while the Stamp Valuation Authority determined its value at ₹46,33,000. The Assessing Officer (AO) reopen...