Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
A reassessment order cannot be revised under section 263 merely because the Principal Commissioner believes further inquiry was desirable, where the Assessing Officer had examined the recorded reasons issue, considered contract notes, bank statements, computation and audited accounts, and accepted the assessee's explanation. The Tribunal held that Explanation 2 to section 263 does not apply absent a finding that the reassessment was made without any enquiry or verification. The reassessment was therefore not erroneous or prejudicial to the interests of the revenue, and the revisional jurisdiction was wrongly assumed; the revision order was quashed.
A reassessment order cannot be revised under section 263 merely because the Principal Commissioner believes further inquiry was desirable, where the Assessing Officer had examined the recorded reasons issue, considered contract notes, bank statements, computation and audited accounts, and accepted the assessee's explanation. The Tribunal held that Explanation 2 to section 263 does not apply absent a finding that the reassessment was made without any enquiry or verification. The reassessment was therefore not erroneous or prejudicial to the interests of the revenue, and the revisional jurisdiction was wrongly assumed; the revision order was quashed.
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