Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Rectification u/s 154 - under-assessment of income qua the foregoing depreciation/additional depreciation issue(s) - The Tribunal considered the Revenue’s contentions but found no merit in them. It was observed that the rectification proceedings under section 154 initiated by the Assessing Officer were not sustainable, as they involved a detailed re-computation of the assessee’s depreciation claims, which went beyond rectifying apparent mistakes on record. - In light of the decision of Supreme Court, the Tribunal dismissed the Revenue’s appeal, affirming the CIT(A)’s decision.
Rectification u/s 154 - under-assessment of income qua the foregoing depreciation/additional depreciation issue(s) - The Tribunal considered the Revenue’s contentions but found no merit in them. It was observed that the rectification proceedings under section 154 initiated by the Assessing Officer were not sustainable, as they involved a detailed re-computation of the assessee’s depreciation claims, which went beyond rectifying apparent mistakes on record. - In light of the decision of Supreme Court, the Tribunal dismissed the Revenue’s appeal, affirming the CIT(A)’s decision.
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