Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Revision u/s 263 by CIT - PCIT could not merely sit solely in the capacity of a revisional authority qua the new material but was required to perform the task of AO in tandem and discharge quasi-judicial function independently. - PCIT has failed to do so. Neither the purported evidence collected from SEBI were confronted nor the cross examination of adversarial statement was provided. The opportunity contemplated under S. 263 is thus rendered illusory and merely an empty formality resulting in miscarriage of justice in contravention of expresses intendment of law. - AT
Revision u/s 263 by CIT - PCIT could not merely sit solely in the capacity of a revisional authority qua the new material but was required to perform the task of AO in tandem and discharge quasi-judicial function independently. - PCIT has failed to do so. Neither the purported evidence collected from SEBI were confronted nor the cross examination of adversarial statement was provided. The opportunity contemplated under S. 263 is thus rendered illusory and merely an empty formality resulting in miscarriage of justice in contravention of expresses intendment of law. - AT
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