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    Revisional power cannot replace a plausible assessment view when inquiry was made into bogus purchases.
    Consequential assessment under revision loses force when section 263 orders are remanded; appeal becomes infructuous.
    Make available test bars tax on management and business support fees under India-Singapore treaty, deleting the addition
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      Seeking rectification of an alleged mistake - question of...

      Tribunal Dismisses Request for Rectification Due to Jurisdiction Issues; Submissions Presumed as Appellant's Instructions.

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      CustomsMarch 21, 2024Case LawsAT
      Seeking rectification of an alleged mistake - question of jurisdiction of this tribunal - error apparent on the face of record or not - The Tribunal rejected the appellant's claim, stating that it had considered the jurisdiction issue in light of previous judgments and amendments. Since both parties chose not to argue the jurisdiction issue during the hearing, the Tribunal proceeded to decide the case on its merits. - The Tribunal emphasized that when a counsel makes submissions, it is presumed to be on the instructions of the appellant. Hiring a new counsel post-judgment to raise new grounds or find fault with the previous counsel's submissions is not a valid approach.

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      ActsIncome Tax