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...
Section 264 provides beneficial and remedial revisional relief against over-assessment, including errors in a taxpayer's return. Relief is not dependent on filing a revised return within the prescribed time or on whether the error arose from the taxpayer's voluntary action or a departmental order. Taxing the same income in two assessment years can create an over-assessment where the combined effect of the relevant orders results in double taxation. A revisional authority must examine the claim and reconciliations on their merits rather than reject relief solely because an intimation accepted the returned income in isolation.
Section 264 provides beneficial and remedial revisional relief against over-assessment, including errors in a taxpayer's return. Relief is not dependent on filing a revised return within the prescribed time or on whether the error arose from the taxpayer's voluntary action or a departmental order. Taxing the same income in two assessment years can create an over-assessment where the combined effect of the relevant orders results in double taxation. A revisional authority must examine the claim and reconciliations on their merits rather than reject relief solely because an intimation accepted the returned income in isolation.
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