Revision Order Under Section 263 Set Aside as PCIT's Assumptions Not Prejudicial to Revenue Interests

The ITAT set aside the PCIT's revision order under section 263, finding it was based on assumptions and not prejudicial to revenue interests. The Tribunal determined that section 69 was inapplicable as the assessee had adequately explained investment sources during the survey. The PCIT's calculations regarding valuation differences were incorrect, as the Rs.12,143 surrender was based on estimated valuation reports. Regarding ESI payments, the PCIT erroneously calculated Rs.17,298 instead of the actual Rs.9,819. The Tribunal noted that disallowance of late ESI/PF payments was improper, and the AO had properly verified these issues. The section 115BBE invocation was invalid as investment sources were explained and verified. The assessee's appeal was allowed. .....

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