Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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