Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
Revision u/s 263 - 56(2)(x)(c)(B) - FMV purchases exceeds the price of shares - The tribunal observed that, the option to adopt either NAV or DCF Method for valuing the shares has been given to an Assessee in the statute itself. When the A.O. has appreciated this option availed by the Assessee, his order cannot be construed as erroneous. - Further, it is observed that it is not a case wherein the Assessing Officer failed to conduct enquiry rather it is the case wherein the AO has conducted an elaborate enquiry and adopted one of the two views which was plausible view. - Consequently, the ITAT following the decision of Supreme Court, quashed the revision order.
Revision u/s 263 - 56(2)(x)(c)(B) - FMV purchases exceeds the price of shares - The tribunal observed that, the option to adopt either NAV or DCF Method for valuing the shares has been given to an Assessee in the statute itself. When the A.O. has appreciated this option availed by the Assessee, his order cannot be construed as erroneous. - Further, it is observed that it is not a case wherein the Assessing Officer failed to conduct enquiry rather it is the case wherein the AO has conducted an elaborate enquiry and adopted one of the two views which was plausible view. - Consequently, the ITAT following the decision of Supreme Court, quashed the revision order.
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