Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
In the ITAT Jaipur case, the issue revolved around a revision u/s 263 by CIT concerning the assessee's case under limited scrutiny u/s 143(3). The primary focus was on payments to specified persons and a percentage disallowance on salary payments. The tribunal held that the AO had conducted inquiries and verified details submitted by the assessee, allowing the salary payments. The observations by the PCIT were based on a different assessment year, and a disallowance in one year cannot be the basis for doubting claims in another year. The tribunal concluded that the revision proceedings by the PCIT were beyond jurisdiction and against legal principles, quashing the order u/s 263 and allowing the assessee's appeal.
In the ITAT Jaipur case, the issue revolved around a revision u/s 263 by CIT concerning the assessee's case under limited scrutiny u/s 143(3). The primary focus was on payments to specified persons and a percentage disallowance on salary payments. The tribunal held that the AO had conducted inquiries and verified details submitted by the assessee, allowing the salary payments. The observations by the PCIT were based on a different assessment year, and a disallowance in one year cannot be the basis for doubting claims in another year. The tribunal concluded that the revision proceedings by the PCIT were beyond jurisdiction and against legal principles, quashing the order u/s 263 and allowing the assessee's appeal.
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