Mere Difference Of Opinion With AO Is No Basis To Exercise Revisionary Power U/s 263: Chandigarh ITAT Confirms Sec 80P Deduction Granted By AO

The Chandigarh ITAT nullified the revision order under Section 263 of the Income Tax Act, emphasizing the necessity for the Commissioner's satisfaction to be objectively justifiable and based on available legal or factual material rather than a mere difference in opinion with the assessing officer. \r

The case involved a cooperative society claiming deductions under Section 80P(2)(d) for interest earned from investments in cooperative banks. \r

Despite the Commissioner's contention that the society was ineligible for the deduction, the ITAT found that the assessing officer had adequately examined the claim during the original assessment, thus deeming the revisionary action invalid. Advocate Tej Mohan Singh represented the Assessee, while Garima Singh represented the Revenue.