Territorial jurisdiction in income-tax appeals follows the assessing officer's location, not the Tribunal's seat or a subsequent acquirer's registered...
Transfer pricing comparables must reflect functional similarity, with diverse activities and asset profiles supporting exclusion from contract service...
Real income in electricity distribution excludes surcharges and regulatory assets without reasonably certain recovery, while deductions require return...
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Section 43CA permits substitution of actual property sale consideration with the stamp duty valuation only where the valuation exceeds the consideration. It does not empower the Assessing Officer to question a valuation certificate issued by the Stamp Duty Authority. Revision under section 263 requires an assessment to be erroneous and prejudicial to Revenue interests. Failure to question the certificate and a direction to refer the valuation to the Stamp Duty Authority cannot establish such an error where the revision rests on incorrect facts and requires examination beyond Revenue authorities' powers.
Section 43CA permits substitution of actual property sale consideration with the stamp duty valuation only where the valuation exceeds the consideration. It does not empower the Assessing Officer to question a valuation certificate issued by the Stamp Duty Authority. Revision under section 263 requires an assessment to be erroneous and prejudicial to Revenue interests. Failure to question the certificate and a direction to refer the valuation to the Stamp Duty Authority cannot establish such an error where the revision rests on incorrect facts and requires examination beyond Revenue authorities' powers.
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