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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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