Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
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Revision u/s 263 - PCIT is incorrect in coming to the conclusion that Assessing Officer has not examined the issue and applied his mind insofar as investments in fixed deposits - once the Assessing Officer has taken one of the two views permissible in law on which the PCIT does not agree and which resulted in loss of revenue, it cannot be treated as erroneous order prejudicial to the interests of the revenue, unless the view taken by the Assessing Officer is completely unsustainable in law. - AT
Revision u/s 263 - PCIT is incorrect in coming to the conclusion that Assessing Officer has not examined the issue and applied his mind insofar as investments in fixed deposits - once the Assessing Officer has taken one of the two views permissible in law on which the PCIT does not agree and which resulted in loss of revenue, it cannot be treated as erroneous order prejudicial to the interests of the revenue, unless the view taken by the Assessing Officer is completely unsustainable in law. - AT
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