Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
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...
An assessment can be revised under section 263 where the Assessing Officer makes no specific enquiry or proper verification of a deduction claim or business loss claim. Mere calling for general details, without follow-up examination, does not show application of mind. On the record described, no discernible opinion had been formed on the section 54B claim or the petrol and diesel evaporation loss, so the matter was not one of change of opinion. Applying Explanation 2(a), such an assessment is treated as erroneous and prejudicial to the Revenue, and the revisional order was sustained.
An assessment can be revised under section 263 where the Assessing Officer makes no specific enquiry or proper verification of a deduction claim or business loss claim. Mere calling for general details, without follow-up examination, does not show application of mind. On the record described, no discernible opinion had been formed on the section 54B claim or the petrol and diesel evaporation loss, so the matter was not one of change of opinion. Applying Explanation 2(a), such an assessment is treated as erroneous and prejudicial to the Revenue, and the revisional order was sustained.
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