Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
The AO's order was not erroneous or prejudicial to the revenue's interests. The filing fee for increasing share capital was rightly allowed as revenue expenditure, supported by audited financials and judicial precedent. The AO examined the revised computation, disallowed deduction u/s 35ABB after due application of mind, and passed the assessment order at the originally returned income. The PCIT's revision u/s 263, deeming the AO's order erroneous and prejudicial, is unjustified and quashed. The assessee's appeal is allowed.
The AO's order was not erroneous or prejudicial to the revenue's interests. The filing fee for increasing share capital was rightly allowed as revenue expenditure, supported by audited financials and judicial precedent. The AO examined the revised computation, disallowed deduction u/s 35ABB after due application of mind, and passed the assessment order at the originally returned income. The PCIT's revision u/s 263, deeming the AO's order erroneous and prejudicial, is unjustified and quashed. The assessee's appeal is allowed.
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