Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Employee conflict disclosures and investment restrictions expand with new recusal duties, post-employment limits, and compliance reporting requirement...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
