Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
For assessment orders passed before 1 April 2025, the Assessing Officer lacked jurisdiction to impose or initiate penalty proceedings for contravention of cash loan or deposit restrictions under section 271D. Non-initiation of such penalty proceedings therefore could not make the assessment order erroneous and prejudicial to the interests of the Revenue for revision under section 263. A revisionary order founded solely on that omission was set aside, and the taxpayer's appeal was allowed.
For assessment orders passed before 1 April 2025, the Assessing Officer lacked jurisdiction to impose or initiate penalty proceedings for contravention of cash loan or deposit restrictions under section 271D. Non-initiation of such penalty proceedings therefore could not make the assessment order erroneous and prejudicial to the interests of the Revenue for revision under section 263. A revisionary order founded solely on that omission was set aside, and the taxpayer's appeal was allowed.
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