Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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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