Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
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...
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Revisionary jurisdiction under section 263 may be invoked where the assessment record gives a prima facie basis to regard an assessment as both erroneous and prejudicial to Revenue; final determination follows inquiry and hearing. A co-operative society deduction requires examination of the timely-return condition under section 80AC. Queries into cash deposits do not satisfy that obligation where they do not address the separate statutory eligibility condition, and a return furnished only after a reopening notice does not meet the prescribed filing requirement. Reassessment may examine the deduction when claimed co-operative income is offered to explain the cash deposits that prompted reopening. The revision was sustained and the appeal dismissed.
Revisionary jurisdiction under section 263 may be invoked where the assessment record gives a prima facie basis to regard an assessment as both erroneous and prejudicial to Revenue; final determination follows inquiry and hearing. A co-operative society deduction requires examination of the timely-return condition under section 80AC. Queries into cash deposits do not satisfy that obligation where they do not address the separate statutory eligibility condition, and a return furnished only after a reopening notice does not meet the prescribed filing requirement. Reassessment may examine the deduction when claimed co-operative income is offered to explain the cash deposits that prompted reopening. The revision was sustained and the appeal dismissed.
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