Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Revision under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. The distinction between lack of inquiry and inadequate inquiry is material: where the Assessing Officer has examined relevant expenses, related-party payments, GST-exempt services, financial records, returns, GST details, TDS particulars and supplier-level material, revision cannot be based merely on a view that further verification was desirable. The revisional authority must identify an actual error from the assessment record and demonstrate resulting prejudice; it cannot order a fresh investigation without establishing both statutory conditions. The stated result was quashing of the revisionary order and allowance of the assessee's appeal.
Revision under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. The distinction between lack of inquiry and inadequate inquiry is material: where the Assessing Officer has examined relevant expenses, related-party payments, GST-exempt services, financial records, returns, GST details, TDS particulars and supplier-level material, revision cannot be based merely on a view that further verification was desirable. The revisional authority must identify an actual error from the assessment record and demonstrate resulting prejudice; it cannot order a fresh investigation without establishing both statutory conditions. The stated result was quashing of the revisionary order and allowance of the assessee's appeal.
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