Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Section 263 revision requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where the Assessing Officer has called for and considered details on unsecured loans and trade payables, revision cannot rest merely on audit objections or an assumption that further inquiry would produce an addition under section 68. Explanation 2 creates a deeming framework for insufficient inquiry but does not remove the twin statutory requirements. In the stated circumstances, the assessment was made after inquiry, no revenue prejudice was identified, and the revisional order was quashed.
Section 263 revision requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where the Assessing Officer has called for and considered details on unsecured loans and trade payables, revision cannot rest merely on audit objections or an assumption that further inquiry would produce an addition under section 68. Explanation 2 creates a deeming framework for insufficient inquiry but does not remove the twin statutory requirements. In the stated circumstances, the assessment was made after inquiry, no revenue prejudice was identified, and the revisional order was quashed.
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