Section 263 Revision Invalid: AO's Treatment of Disclosed Income During Survey Valid After Proper Inquiry Through Show Cause Notice

ITAT held revisionary powers under s.263 cannot be invoked as assessment order was neither erroneous nor prejudicial to Revenue's interests. During survey, assessee surrendered undisclosed income which was included in tax returns. AO conducted specific inquiry regarding applicability of s.115BBE through show cause notice. PCIT cannot merely substitute their view that income should be treated as unexplained investment under s.69 (Rs.66,50,000) and unexplained money under s.69A (Rs.9,50,000). Amendment via Explanation 2(a) expanding revisionary powers does not grant unlimited authority. No errors of law or fact were found in AO's order, which represented a plausible interpretation after proper inquiry. Appeal decided in assessee's favor. .....

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