Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Revision u/s 263 - Computation of capital gain/loss - reduction of the paid up equity share capital consequent to scheme of arrangement and restructuring - we are not relying upon the minority judgment but we have to bear in mind that this is a case under revisionary jurisdiction u/s. 263 wherein the ld. PCIT has cancelled the order of the ld. AO who has accepted the long term capital loss. The dissenting judgment goes to show that it is possible view and therefore, if a view has been taken by the AO in favour of the assessee, then it could not be held that order of AO is erroneous and therefore, can be set aside or cancelled. - AT
Revision u/s 263 - Computation of capital gain/loss - reduction of the paid up equity share capital consequent to scheme of arrangement and restructuring - we are not relying upon the minority judgment but we have to bear in mind that this is a case under revisionary jurisdiction u/s. 263 wherein the ld. PCIT has cancelled the order of the ld. AO who has accepted the long term capital loss. The dissenting judgment goes to show that it is possible view and therefore, if a view has been taken by the AO in favour of the assessee, then it could not be held that order of AO is erroneous and therefore, can be set aside or cancelled. - AT
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