Customs Broker association membership becomes mandatory in the operating jurisdiction, with exclusive membership and limited compliance-time relaxatio...
Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
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The High Court held that the Commissioner of Income-Tax, while exercising revisionary powers u/s 264 of the Income Tax Act, is duty-bound to consider the revision petition on merits. The term 'record' in Section 264 should be interpreted broadly, as per the Central Board of Direct Taxes' circular. Consequently, the order u/s 144A should have been considered part of the record by the Commissioner while deciding the revision petition u/s 264. The impugned orders passed u/ss 264 and 154 were quashed, and the matter was remanded to the Principal Commissioner to decide the revision petition u/s 264 on merits, considering the order u/s 144A as part of the record.
The High Court held that the Commissioner of Income-Tax, while exercising revisionary powers u/s 264 of the Income Tax Act, is duty-bound to consider the revision petition on merits. The term 'record' in Section 264 should be interpreted broadly, as per the Central Board of Direct Taxes' circular. Consequently, the order u/s 144A should have been considered part of the record by the Commissioner while deciding the revision petition u/s 264. The impugned orders passed u/ss 264 and 154 were quashed, and the matter was remanded to the Principal Commissioner to decide the revision petition u/s 264 on merits, considering the order u/s 144A as part of the record.
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