Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
The assessee's appeal against the Commissioner's revision order u/s 263 was dismissed. The Tribunal held that the Assessing Officer (AO), after reopening the assessment u/s 147, failed to conduct a detailed inquiry and verification regarding the reasons for reopening and the genuineness of the transactions. The order passed u/s 147 read with Section 144B lacked findings on these aspects, rendering it erroneous and prejudicial to the Revenue's interests. The Tribunal rejected the contentions regarding non-application of mind by the Commissioner and the invalidity of the order u/s 147 due to non-addition of income. It held that the AO can make additions on other issues even if no addition is made for the reasons for reopening, and the order u/s 147 does not become invalid merely because the returned income was accepted. The Tribunal affirmed the Commissioner's revisionary jurisdiction u/s 263 in such cases.
The assessee's appeal against the Commissioner's revision order u/s 263 was dismissed. The Tribunal held that the Assessing Officer (AO), after reopening the assessment u/s 147, failed to conduct a detailed inquiry and verification regarding the reasons for reopening and the genuineness of the transactions. The order passed u/s 147 read with Section 144B lacked findings on these aspects, rendering it erroneous and prejudicial to the Revenue's interests. The Tribunal rejected the contentions regarding non-application of mind by the Commissioner and the invalidity of the order u/s 147 due to non-addition of income. It held that the AO can make additions on other issues even if no addition is made for the reasons for reopening, and the order u/s 147 does not become invalid merely because the returned income was accepted. The Tribunal affirmed the Commissioner's revisionary jurisdiction u/s 263 in such cases.
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