Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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Validity of Revision u/s 263 - The tribunal held that the exercise of the second revision jurisdiction by the PCIT on the same issue was not justified. It noted that the AO had made necessary inquiries as per the directions of the first PCIT and that the assessee had provided sufficient evidence to prove the identity, creditworthiness, and genuineness of the share subscribers.
Validity of Revision u/s 263 - The tribunal held that the exercise of the second revision jurisdiction by the PCIT on the same issue was not justified. It noted that the AO had made necessary inquiries as per the directions of the first PCIT and that the assessee had provided sufficient evidence to prove the identity, creditworthiness, and genuineness of the share subscribers.
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