Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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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