International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Revision u/s 263 - validity of notice as issued by the ITO who is below the rank of ld. PCIT - The statute never permitted in section 263 for delegation of power to the authority below for issuance of notice for initiation of proceedings. - The delegation if possible if permitted by the law. DR was unable to place any judgment against the submission of assessee. Accordingly, the notice issued U/s 263 is invalid. - AT
Revision u/s 263 - validity of notice as issued by the ITO who is below the rank of ld. PCIT - The statute never permitted in section 263 for delegation of power to the authority below for issuance of notice for initiation of proceedings. - The delegation if possible if permitted by the law. DR was unable to place any judgment against the submission of assessee. Accordingly, the notice issued U/s 263 is invalid. - AT
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