Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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