Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Revision of an assessment for lack of inquiry requires an erroneous and prejudicial order, not merely a different view of matters examined during scrutiny. Where the Assessing Officer made inquiries into depreciation on fixed assets, commission paid to a non-resident, and deductions for employing new workmen, and applied mind to the responses, revision was not sustainable. The Principal Commissioner had identified neither a flaw in the assessee's replies nor a specific defect in the prescribed audit report. The revision order was quashed, and the tax appeal was dismissed because the Tribunal's findings disclosed no legal infirmity.
Revision of an assessment for lack of inquiry requires an erroneous and prejudicial order, not merely a different view of matters examined during scrutiny. Where the Assessing Officer made inquiries into depreciation on fixed assets, commission paid to a non-resident, and deductions for employing new workmen, and applied mind to the responses, revision was not sustainable. The Principal Commissioner had identified neither a flaw in the assessee's replies nor a specific defect in the prescribed audit report. The revision order was quashed, and the tax appeal was dismissed because the Tribunal's findings disclosed no legal infirmity.
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