Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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Revision u/s 263 by CIT - claim of exemption u/s 54B towards long term capital gain on sale of land when no such claim u/s 54B - Scope of the amendment made in section 263 w.e.f. 01.06.2015. - the intention of the legislature could not have been to enable the Ld. PCIT to find fault with each and every assessment order, without conducting any enquiry or verification in order to establish that the assessment order is not sustainable in law, since such an interpretation will lead to unending litigation and there would not be any point of finality in the legal proceedings. The opinion of the Ld. PCIT referred to in section 263 of the Act has to be understood as legal and judicious opinion and not arbitrary opinion. - AT
Revision u/s 263 by CIT - claim of exemption u/s 54B towards long term capital gain on sale of land when no such claim u/s 54B - Scope of the amendment made in section 263 w.e.f. 01.06.2015. - the intention of the legislature could not have been to enable the Ld. PCIT to find fault with each and every assessment order, without conducting any enquiry or verification in order to establish that the assessment order is not sustainable in law, since such an interpretation will lead to unending litigation and there would not be any point of finality in the legal proceedings. The opinion of the Ld. PCIT referred to in section 263 of the Act has to be understood as legal and judicious opinion and not arbitrary opinion. - AT
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