Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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