Statutory refund interest requires correction of short computation and compensation where admitted interest remains unpaid through administrative dela...
Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
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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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