On appeal Tribunal held, that PCIT failed to make out a proper case for revision of the Order passed u/s. 143(3), and overturned the order, citing following reasons:

• Firstly, various objections raised by PCIT has no relevance in the matter, in granting deduction u/s. 54F.
• Also the observation of the PCIT, that A.O failed to enquire and verify the issues is not correct, more so, when the assessee on an inquiry furnished all the details, and necessary evidences to corroborate the claim was filed during assessment proceedings which was evident from the order sheet entries
• Mere doubt cannot lead to revision of an order unless it is proved that AO failed to apply his mind, or that his view was wrong in facts or in law
• AO having examined the issue, and being convinced, and not making any disallowance the order passed u/s 143(3) cannot be said to be erroneous and prejudicial order (AY. 2014-15)