Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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Revision u/s 263 - The records of the instant case speaks that no details were filed by the assessee before the Ld. A.O to prove the reasonableness of payments made to relatives nor any indication is there on behalf of the Ld. A.O to call for specific details relating to payment to relatives u/s 40A(2)(b) of the Act. Thus in our considered view there is “no enquiry” about the reasons No.4 i.e mismatch in amount paid to related persons u/s 40A(2)(b) and therefore Ld. PCITT has rightly invoked his power u/s 263 of the Act setting aside the order of Ld. A.O with regard to these reasons.
Revision u/s 263 - The records of the instant case speaks that no details were filed by the assessee before the Ld. A.O to prove the reasonableness of payments made to relatives nor any indication is there on behalf of the Ld. A.O to call for specific details relating to payment to relatives u/s 40A(2)(b) of the Act. Thus in our considered view there is “no enquiry” about the reasons No.4 i.e mismatch in amount paid to related persons u/s 40A(2)(b) and therefore Ld. PCITT has rightly invoked his power u/s 263 of the Act setting aside the order of Ld. A.O with regard to these reasons.
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