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...
Scope of rectification u/s 154 - Allowing the rectification application CIT(A) admitted the claim of expenditure - The ITAT concluded that the question of comparables in the appellant's business line involved subjective adjudication and detailed inquiries, which were beyond the scope of rectification proceedings under Section 154. Citing the precedent set by the Supreme Court, the ITAT emphasized that rectification is meant for correcting apparent mistakes on record, not for conducting detailed investigations. - The Revenue's appeal was allowed on the grounds that the appellant's rectification was not maintainable, as the Assessing Officer's findings had not been reversed by the NFAC.
Scope of rectification u/s 154 - Allowing the rectification application CIT(A) admitted the claim of expenditure - The ITAT concluded that the question of comparables in the appellant's business line involved subjective adjudication and detailed inquiries, which were beyond the scope of rectification proceedings under Section 154. Citing the precedent set by the Supreme Court, the ITAT emphasized that rectification is meant for correcting apparent mistakes on record, not for conducting detailed investigations. - The Revenue's appeal was allowed on the grounds that the appellant's rectification was not maintainable, as the Assessing Officer's findings had not been reversed by the NFAC.
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