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2022 (1) TMI 836 - AT - Income TaxRevision u/s 263 by CIT - Addition as income from other sources as the assessee had purchased the property at a cost less than the market value of the property and the property was received for inadequate consideration - HELD THAT:- AO has examined the entire issue during the course of assessment proceedings. It is very clear from the assessment order itself. That apart, the AO has issued a show-cause notice to the assessee and called for explanation. By considering the detailed explanation of the assessee, the AO was of the opinion that where the difference between the actual value and market value is less than 10%, the same is ignorable and does not warrant any taxation. In this case, the Assessing Officer has passed the assessment order after due verification and consideration of detailed written submissions filed by the assessee against the show-cause notice and therefore, we are of the considered opinion that invoking the provisions of section 263 of the Act does not warrant for the reason that the assessment order passed by the Assessing Officer is neither erroneous nor prejudicial to the interest of the Revenue. Accordingly, we quash the revision order passed under section 263 of the Act by the ld. PCIT and allow the appeal of the assessee.
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