Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Revision u/s 263 - The ITAT held that the AO had conducted adequate inquiries into the sales promotion expenses, as evidenced by the issuance of specific queries to the assessee. The AO's decision to accept the assessee's claims was based on the responses and documents provided. The ITAT found that the PCIT's revision under Section 263, alleging non-verification of the said expenses, was not justified as the AO had made necessary inquiries and applied his mind to the information available.
Revision u/s 263 - The ITAT held that the AO had conducted adequate inquiries into the sales promotion expenses, as evidenced by the issuance of specific queries to the assessee. The AO's decision to accept the assessee's claims was based on the responses and documents provided. The ITAT found that the PCIT's revision under Section 263, alleging non-verification of the said expenses, was not justified as the AO had made necessary inquiries and applied his mind to the information available.
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