Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Revision u/s 263 - the Ld. CIT(E) has taken into consideration the incorrect and irrelevant facts to allege that there is no enquiry by the AO and thus the impugned assessment order is erroneous and prejudicial to the interest of the revenue without considering the reply of the assessee to show cause notice u/s. 263 of the Act and keeping aside the basic principles of tax jurisprudence relevant for assessing income of a charitable trust. - AT
Revision u/s 263 - the Ld. CIT(E) has taken into consideration the incorrect and irrelevant facts to allege that there is no enquiry by the AO and thus the impugned assessment order is erroneous and prejudicial to the interest of the revenue without considering the reply of the assessee to show cause notice u/s. 263 of the Act and keeping aside the basic principles of tax jurisprudence relevant for assessing income of a charitable trust. - AT
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