Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The ITAT Jaipur addressed a case involving a revision u/s 263 concerning the addition u/s 68 based on a report from an investigation in Mumbai. The PCIT contended that the AO did not properly examine the issue of bogus LTCG, leading to the need for the LTCG claimed to be added to the assessee's total income. The tribunal emphasized that for u/s 263 to apply, the assessment order must be both erroneous and prejudicial to revenue. Mere loss of revenue due to the AO's decision does not automatically make the order prejudicial. The tribunal found no incorrectness in the AO's actions and concluded that the PCIT's order did not meet the requirements of u/s 263. The tribunal held that a change of opinion by the PCIT is not permissible under the law, ultimately allowing the assessee's appeal.
The ITAT Jaipur addressed a case involving a revision u/s 263 concerning the addition u/s 68 based on a report from an investigation in Mumbai. The PCIT contended that the AO did not properly examine the issue of bogus LTCG, leading to the need for the LTCG claimed to be added to the assessee's total income. The tribunal emphasized that for u/s 263 to apply, the assessment order must be both erroneous and prejudicial to revenue. Mere loss of revenue due to the AO's decision does not automatically make the order prejudicial. The tribunal found no incorrectness in the AO's actions and concluded that the PCIT's order did not meet the requirements of u/s 263. The tribunal held that a change of opinion by the PCIT is not permissible under the law, ultimately allowing the assessee's appeal.
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