Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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