Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Revision u/s 263 - change of opinion - in proceedings u/s 147 assessee contended that the transfer price was based on the individual assets and liabilities of the undertaking transferred and the sale would not qualify as “Slump Sale” as per Section 2(42C) - this explanation of the Assessee was accepted by the AO - for the very same reasons, the CIT has invoked the power u/s 263 - not permissible
Revision u/s 263 - change of opinion - in proceedings u/s 147 assessee contended that the transfer price was based on the individual assets and liabilities of the undertaking transferred and the sale would not qualify as “Slump Sale” as per Section 2(42C) - this explanation of the Assessee was accepted by the AO - for the very same reasons, the CIT has invoked the power u/s 263 - not permissible
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