Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Section 263 revision - Unexplained income u/s 69A read with Section 115BBE - Cash seized shown as 'income from other sources' - Whether to be treated as unexplained income u/s 69A read with Section 115BBE? Held: For invoking Section 263, the Assessing Officer's order should be erroneous and prejudicial to revenue interests. As per Explanation 2(a) to Section 263, an order is deemed erroneous if passed without making required inquiry or verification. In this case, the assessee's claim was unsupported by contemporaneous evidence, and the Assessing Officer failed to verify the same. Hence, there was a failure to make necessary inquiry/verification, rendering the order erroneous and prejudicial to revenue interests. Therefore, the invocation of Section 263 by the Principal Commissioner of Income Tax was as per law. Accordingly, the assessee's appeal on this ground is dismissed.
Section 263 revision - Unexplained income u/s 69A read with Section 115BBE - Cash seized shown as 'income from other sources' - Whether to be treated as unexplained income u/s 69A read with Section 115BBE? Held: For invoking Section 263, the Assessing Officer's order should be erroneous and prejudicial to revenue interests. As per Explanation 2(a) to Section 263, an order is deemed erroneous if passed without making required inquiry or verification. In this case, the assessee's claim was unsupported by contemporaneous evidence, and the Assessing Officer failed to verify the same. Hence, there was a failure to make necessary inquiry/verification, rendering the order erroneous and prejudicial to revenue interests. Therefore, the invocation of Section 263 by the Principal Commissioner of Income Tax was as per law. Accordingly, the assessee's appeal on this ground is dismissed.
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