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...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Revisional jurisdiction under section 264 is benevolent and cannot be used to place an assessee in a worse position; the ITAT held that, while giving effect to the revision, the AO could not reopen matters already accepted and enhance the addition. On facts, the assessee's only income was salary received in cash, that source was undisputed, and the explanation that the balance demonetisation cash deposits came from past salary savings was treated as reasonable despite the absence of further documentation. The addition for unexplained cash deposits was deleted, and the connected duplicate appeal was dismissed.
Revisional jurisdiction under section 264 is benevolent and cannot be used to place an assessee in a worse position; the ITAT held that, while giving effect to the revision, the AO could not reopen matters already accepted and enhance the addition. On facts, the assessee's only income was salary received in cash, that source was undisputed, and the explanation that the balance demonetisation cash deposits came from past salary savings was treated as reasonable despite the absence of further documentation. The addition for unexplained cash deposits was deleted, and the connected duplicate appeal was dismissed.
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