Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Revision u/s 263 disallowing exemption u/s 11(1) for government grant received by assessee-Trust. ITAT concluded Principal CIT did not independently apply mind by calling office records, but acted on Assessing Officer's proposal to initiate Section 263 proceedings, rendering order liable to be set aside. ITAT based on consistency principle and absence of change in facts regarding Trust receiving government grant in earlier years accepted by Revenue for Section 11 exemption eligibility. HC found no erroneous or prejudicial assessment order u/s 143(3), dismissing appeal as no substantial question of law arose from ITAT order.
Revision u/s 263 disallowing exemption u/s 11(1) for government grant received by assessee-Trust. ITAT concluded Principal CIT did not independently apply mind by calling office records, but acted on Assessing Officer's proposal to initiate Section 263 proceedings, rendering order liable to be set aside. ITAT based on consistency principle and absence of change in facts regarding Trust receiving government grant in earlier years accepted by Revenue for Section 11 exemption eligibility. HC found no erroneous or prejudicial assessment order u/s 143(3), dismissing appeal as no substantial question of law arose from ITAT order.
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