Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Validity of Revision u/s 263 - An order which is prejudicial to revenue even if no Tax Loss - The High Court found that the AO's assessment did not adequately address the genuineness and creditworthiness of the loan transactions from certain entities, identified in a DDIT investigation report as shell companies operated by an entry operator. This oversight was deemed a significant inquiry lapse, rendering the assessment order both erroneous and prejudicial to the Revenue's interests. - The Court underscored the principle that an order could be deemed erroneous if it was prejudicial to the Revenue, even if it did not result in immediate tax loss, reflecting a broader interpretation aimed at preserving the Revenue's interests.
Validity of Revision u/s 263 - An order which is prejudicial to revenue even if no Tax Loss - The High Court found that the AO's assessment did not adequately address the genuineness and creditworthiness of the loan transactions from certain entities, identified in a DDIT investigation report as shell companies operated by an entry operator. This oversight was deemed a significant inquiry lapse, rendering the assessment order both erroneous and prejudicial to the Revenue's interests. - The Court underscored the principle that an order could be deemed erroneous if it was prejudicial to the Revenue, even if it did not result in immediate tax loss, reflecting a broader interpretation aimed at preserving the Revenue's interests.
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