Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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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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