Approved gratuity fund provisions remain deductible despite general actual-payment requirements, preventing revision of the allowed gratuity deduction...
Verification of intangible software expenditure and duplicated disallowances requires record-based reassessment before depreciation and income computa...
Cash receipt aggregation requires a single transaction, event or occasion; separate partner capital contributions cannot attract cash-receipt penaltie...
Revision under section 263 may apply where reassessment of alleged bogus purchases lacks requisite verification. Supplier non-response, failure to furnish requested confirmations, evidence of goods movement and transporter payments, and the Assessing Officer's failure to undertake follow-up inquiry indicate inadequate inquiry. Mere issuance of notices and receipt of partial material do not constitute an inquiry reaching a conclusion under Explanation 2(a). An unreasoned profit-rate estimate does not represent a legally sustainable plausible view or a concluded opinion protected by change-of-opinion principles, rendering the assessment erroneous and prejudicial to the interests of the Revenue.
Revision under section 263 may apply where reassessment of alleged bogus purchases lacks requisite verification. Supplier non-response, failure to furnish requested confirmations, evidence of goods movement and transporter payments, and the Assessing Officer's failure to undertake follow-up inquiry indicate inadequate inquiry. Mere issuance of notices and receipt of partial material do not constitute an inquiry reaching a conclusion under Explanation 2(a). An unreasoned profit-rate estimate does not represent a legally sustainable plausible view or a concluded opinion protected by change-of-opinion principles, rendering the assessment erroneous and prejudicial to the interests of the Revenue.
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TaxTMI 
TaxTMI 
of 4925 
