Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Revision u/s 263 - Bogus expenditure towards sub-contract payments made to persons who were previously employed in the assessee’s company as supervisors / garage in-charge for monthly salaries - The Tribunal observed that the AO did not examine payments to subcontractors during assessment proceedings. - The details of sub-contracts were not verified, and claims by the assessee were accepted without inquiry. - The ITAT found the AO's actions to be erroneous and prejudicial to revenue. - Hence, the proceedings under section 263 were rightly initiated.
Revision u/s 263 - Bogus expenditure towards sub-contract payments made to persons who were previously employed in the assessee’s company as supervisors / garage in-charge for monthly salaries - The Tribunal observed that the AO did not examine payments to subcontractors during assessment proceedings. - The details of sub-contracts were not verified, and claims by the assessee were accepted without inquiry. - The ITAT found the AO's actions to be erroneous and prejudicial to revenue. - Hence, the proceedings under section 263 were rightly initiated.
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