Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
Revision u/s 263 - revision based on the audit objection - borrowed satisfaction - The ITAT noted that the AO had called for details and evidence from the appellant and had taken a plausible view based on the information provided. - Despite the PCIT's disagreement with the AO's assessment, the Tribunal held that the order passed by the AO after examination of the issues cannot be deemed erroneous or prejudicial to the revenue's interest. - Additionally, the ITAT found that the PCIT did not establish how the AO's view was incorrect or prejudicial to revenue. The PCIT's order lacked independent justification and was based on borrowed information without adequate satisfaction.
Revision u/s 263 - revision based on the audit objection - borrowed satisfaction - The ITAT noted that the AO had called for details and evidence from the appellant and had taken a plausible view based on the information provided. - Despite the PCIT's disagreement with the AO's assessment, the Tribunal held that the order passed by the AO after examination of the issues cannot be deemed erroneous or prejudicial to the revenue's interest. - Additionally, the ITAT found that the PCIT did not establish how the AO's view was incorrect or prejudicial to revenue. The PCIT's order lacked independent justification and was based on borrowed information without adequate satisfaction.
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