GST payment representations require record-based, reasoned decisions while substantive entitlement remains open for determination by competent authori...
Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Revisionary jurisdiction cannot be invoked merely because a more extensive enquiry is preferred where the Assessing Officer has examined the deduction claim, obtained the statutory audit report and employee-wise details, issued a proposed disallowance notice, and considered the response. Revision requires an erroneous assessment that is prejudicial to Revenue, not simply an allegedly inadequate enquiry. Deduction eligibility is not denied solely because a staffing employer deploys workers at client premises, where it recruits, appoints, pays, reassigns and fulfils statutory employment obligations. Client supervision and salary reimbursement alone do not displace the employer-employee relationship. On these facts, revision for fresh examination was impermissible and the assessment was restored.
Revisionary jurisdiction cannot be invoked merely because a more extensive enquiry is preferred where the Assessing Officer has examined the deduction claim, obtained the statutory audit report and employee-wise details, issued a proposed disallowance notice, and considered the response. Revision requires an erroneous assessment that is prejudicial to Revenue, not simply an allegedly inadequate enquiry. Deduction eligibility is not denied solely because a staffing employer deploys workers at client premises, where it recruits, appoints, pays, reassigns and fulfils statutory employment obligations. Client supervision and salary reimbursement alone do not displace the employer-employee relationship. On these facts, revision for fresh examination was impermissible and the assessment was restored.
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