Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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Revision u/s 263 - block assessment - As per CIT AO failed to include the reserves and surplus for quantification of deemed dividend income - AO has taken a plausible view and there are several decisions of the Hon’ble Supreme Court wherein it has been held that if two views are plausible and the assessing officer takes one of the two views and assigns reasons, such order cannot be construed to be erroneous nor prejudicial to the interest of the revenue - HC
Revision u/s 263 - block assessment - As per CIT AO failed to include the reserves and surplus for quantification of deemed dividend income - AO has taken a plausible view and there are several decisions of the Hon’ble Supreme Court wherein it has been held that if two views are plausible and the assessing officer takes one of the two views and assigns reasons, such order cannot be construed to be erroneous nor prejudicial to the interest of the revenue - HC
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