Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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Section 264(4) does not bar revision merely because the statutory period for filing an appeal has expired. Where no appeal or condonation application is pending and waiver of appeal is not relevant, the Revisional Authority should entertain the revision on merits. Refusal on the premise that the revision is non-maintainable is erroneous, and merits observations founded on that premise cannot stand. The rejection was set aside, with the revision restored for fresh adjudication on merits; all substantive contentions remain open.
Section 264(4) does not bar revision merely because the statutory period for filing an appeal has expired. Where no appeal or condonation application is pending and waiver of appeal is not relevant, the Revisional Authority should entertain the revision on merits. Refusal on the premise that the revision is non-maintainable is erroneous, and merits observations founded on that premise cannot stand. The rejection was set aside, with the revision restored for fresh adjudication on merits; all substantive contentions remain open.
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