Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
Assessee arrived at business income after setting off losses. Assessee's entitlement to carry forward losses was revised due to application of Section 79. Case was reopened u/s 147 after obtaining approval u/s 148, citing revision of assessee's entitlement to carry forward losses due to Section 79 application. Claims were examined during original assessment proceedings, and no error prejudicial to Revenue's interests was found. Inadequate inquiry by Assessing Officer regarding certain claims does not warrant invoking Section 263 powers. Revenue failed to establish that Commissioner exercised power in accordance with law. Facts do not fulfill twin conditions of Section 263. Decided in favor of assessee.
Assessee arrived at business income after setting off losses. Assessee's entitlement to carry forward losses was revised due to application of Section 79. Case was reopened u/s 147 after obtaining approval u/s 148, citing revision of assessee's entitlement to carry forward losses due to Section 79 application. Claims were examined during original assessment proceedings, and no error prejudicial to Revenue's interests was found. Inadequate inquiry by Assessing Officer regarding certain claims does not warrant invoking Section 263 powers. Revenue failed to establish that Commissioner exercised power in accordance with law. Facts do not fulfill twin conditions of Section 263. Decided in favor of assessee.
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