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...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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The Commissioner's invocation of Section 263 for revision of the assessment order was unjustified as the twin conditions of the order being erroneous and prejudicial to revenue interests were not satisfied. The Assessing Officer had issued a specific show cause notice regarding treatment of excess stock as unexplained investment u/s 69, which the assessee explained, and the AO accepted one of the possible views. The ITAT rightly held that the AO's order, passed after due inquiry, was not erroneous or prejudicial to revenue interests, thereby setting aside the Commissioner's revisionary action u/s 263. The decision favored the assessee.
The Commissioner's invocation of Section 263 for revision of the assessment order was unjustified as the twin conditions of the order being erroneous and prejudicial to revenue interests were not satisfied. The Assessing Officer had issued a specific show cause notice regarding treatment of excess stock as unexplained investment u/s 69, which the assessee explained, and the AO accepted one of the possible views. The ITAT rightly held that the AO's order, passed after due inquiry, was not erroneous or prejudicial to revenue interests, thereby setting aside the Commissioner's revisionary action u/s 263. The decision favored the assessee.
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