Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Revision u/s 263 by CIT - addition u/s 40A ignored by AO - expenses have been incurred in cash exceeding Rs. 20,000/- per day - AO is expected to examine the provisions of section 40A(3) vis-à-vis respective transactions and determine which all these transactions are covered by the provisions of section 40A(3) and which all transactions fall under the exception as so provided in the Rule 6DD and decide accordingly. - AO has failed to examine and invoke at first place - Revision sustained - AT
Revision u/s 263 by CIT - addition u/s 40A ignored by AO - expenses have been incurred in cash exceeding Rs. 20,000/- per day - AO is expected to examine the provisions of section 40A(3) vis-à-vis respective transactions and determine which all these transactions are covered by the provisions of section 40A(3) and which all transactions fall under the exception as so provided in the Rule 6DD and decide accordingly. - AO has failed to examine and invoke at first place - Revision sustained - AT
Note: It is a system-generated summary and is for quick reference only.