Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
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Validity of revision proceedings u/s 263 - Adoption of either of view by AO - allowability under section 36(1)(viia) - The court concludes that the original assessment order was not erroneous or prejudicial to the interest of revenue. It holds that the AO's decision was based on a possible view, and therefore, the revision proceedings initiated by the PCIT under section 263 are deemed invalid. Consequently, the appeal of the assessee is allowed.
Validity of revision proceedings u/s 263 - Adoption of either of view by AO - allowability under section 36(1)(viia) - The court concludes that the original assessment order was not erroneous or prejudicial to the interest of revenue. It holds that the AO's decision was based on a possible view, and therefore, the revision proceedings initiated by the PCIT under section 263 are deemed invalid. Consequently, the appeal of the assessee is allowed.
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