Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Revision under section 263 cannot be sustained on grounds not set out in the show cause notice, and the Principal Commissioner cannot introduce a fresh allegation of non-verification of expenses at the revision stage without confronting the assessee. The article also explains that a transfer of an outstanding loan balance by journal entry under a tripartite arrangement is not an actual repayment of loan, so the alleged breach of section 269T and penalty under section 271E did not arise. Where the Assessing Officer had already made enquiries and recorded the assessee's explanation, revision could not rest on a mere view that the enquiry was inadequate. In the absence of a demonstrated error causing prejudice to the Revenue, section 263 was held inapplicable.
Revision under section 263 cannot be sustained on grounds not set out in the show cause notice, and the Principal Commissioner cannot introduce a fresh allegation of non-verification of expenses at the revision stage without confronting the assessee. The article also explains that a transfer of an outstanding loan balance by journal entry under a tripartite arrangement is not an actual repayment of loan, so the alleged breach of section 269T and penalty under section 271E did not arise. Where the Assessing Officer had already made enquiries and recorded the assessee's explanation, revision could not rest on a mere view that the enquiry was inadequate. In the absence of a demonstrated error causing prejudice to the Revenue, section 263 was held inapplicable.
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