Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
Duplicate PAN cancellation timeframe requires prior administrative representation before judicial intervention, ensuring a time-bound decision on the ...
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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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