Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
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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