Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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Revision under section 263 is not warranted where the Assessing Officer has made specific enquiries, examined supporting documents, permissions and valuation details, and taken a view on a trust's advance to a specified person. The assessment was therefore not erroneous and prejudicial to the interests of the Revenue merely because the revisional authority wanted a further or different examination. The text further notes that the alleged charitable trust violation did not justify revision because the record showed full and proper enquiry into the transaction, so the revisional order was set aside.
Revision under section 263 is not warranted where the Assessing Officer has made specific enquiries, examined supporting documents, permissions and valuation details, and taken a view on a trust's advance to a specified person. The assessment was therefore not erroneous and prejudicial to the interests of the Revenue merely because the revisional authority wanted a further or different examination. The text further notes that the alleged charitable trust violation did not justify revision because the record showed full and proper enquiry into the transaction, so the revisional order was set aside.
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