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Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
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Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
The ITAT upheld the Revision u/s 263 by PCIT, finding the AO's assessment under section 143(3) r.w.s. 153C erroneous and prejudicial to Revenue. The unsigned assessment order in ITBA portal was deemed immaterial for invoking u/s 263. PCIT's direction for fresh assessment was justified as AO omitted to consider share profits. Proposed addition under u/s 69A was exempted u/s 10(2A) as firm was separately assessed. PCIT's direction on share of profit verification was upheld as no evidence showed it related to earlier years. PCIT's order was not cryptic and PCIT rightly found AO's assessment prejudicial to Revenue. The grounds challenging PCIT's decision were dismissed.
The ITAT upheld the Revision u/s 263 by PCIT, finding the AO's assessment under section 143(3) r.w.s. 153C erroneous and prejudicial to Revenue. The unsigned assessment order in ITBA portal was deemed immaterial for invoking u/s 263. PCIT's direction for fresh assessment was justified as AO omitted to consider share profits. Proposed addition under u/s 69A was exempted u/s 10(2A) as firm was separately assessed. PCIT's direction on share of profit verification was upheld as no evidence showed it related to earlier years. PCIT's order was not cryptic and PCIT rightly found AO's assessment prejudicial to Revenue. The grounds challenging PCIT's decision were dismissed.
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