Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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Revision u/s 263 - during the course of assessment, the AO made an addition on account of unexplained cash credit of unsecured loan u/s 68 - AO omitted to disallow the interest paid on the said unsecured loan while finalising the scrutiny assessment, which has resulted in under assessment of income. In our view, in the instant facts, the Principal CIT has not erred in facts and in law in setting aside the assessment order u/s. 263 of the Act by holding that the order is erroneous and prejudicial to the interests of the Revenue - AT
Revision u/s 263 - during the course of assessment, the AO made an addition on account of unexplained cash credit of unsecured loan u/s 68 - AO omitted to disallow the interest paid on the said unsecured loan while finalising the scrutiny assessment, which has resulted in under assessment of income. In our view, in the instant facts, the Principal CIT has not erred in facts and in law in setting aside the assessment order u/s. 263 of the Act by holding that the order is erroneous and prejudicial to the interests of the Revenue - AT
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