Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Revision u/s 263 - selection of the case under limited scrutiny - expansion scope of limited scrutiny - As per CIT high sea sales is speculative transaction and therefore disallowance of loss arising therefrom against the non speculative business income - AO cannot go beyond reasons for of limited scrutiny and thus, it would not be open to the PCIT to pass revisionary order u/s 263 on other aspects and remit matter to AO for fresh assessment. - AT
Revision u/s 263 - selection of the case under limited scrutiny - expansion scope of limited scrutiny - As per CIT high sea sales is speculative transaction and therefore disallowance of loss arising therefrom against the non speculative business income - AO cannot go beyond reasons for of limited scrutiny and thus, it would not be open to the PCIT to pass revisionary order u/s 263 on other aspects and remit matter to AO for fresh assessment. - AT
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