Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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Revision under section 263 of issues unrelated to a reassessment is subject to limitation from the original assessment order, not the reassessment order. Where reassessment was confined to alleged bogus purchases, expenditure on gifts to doctors, disallowance under section 14A, and deduction for CSR expenditure under section 80G remained matters examined in the original scrutiny assessment. Audit objections did not permit expansion of reassessment or circumvention of the statutory time limit through revision. The article notes that Supreme Court decisions in Alagendran Finance Ltd. and Industrial Development Bank of India Ltd. prevail over a contrary Tribunal view. Accordingly, the revisionary order was time-barred, quashed, and the assessee's appeal allowed.
Revision under section 263 of issues unrelated to a reassessment is subject to limitation from the original assessment order, not the reassessment order. Where reassessment was confined to alleged bogus purchases, expenditure on gifts to doctors, disallowance under section 14A, and deduction for CSR expenditure under section 80G remained matters examined in the original scrutiny assessment. Audit objections did not permit expansion of reassessment or circumvention of the statutory time limit through revision. The article notes that Supreme Court decisions in Alagendran Finance Ltd. and Industrial Development Bank of India Ltd. prevail over a contrary Tribunal view. Accordingly, the revisionary order was time-barred, quashed, and the assessee's appeal allowed.
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