Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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