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Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
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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