Handicraft job work receives concessional GST only for registered principals and predominantly handmade goods; commercial resin articles remain taxabl...
Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
The HC held that the CIT's revision order u/s 263 was unsustainable. The CIT's view that the transfer of shares by the assessee was a sham to avoid DDT u/s 115-O was misplaced as the perceived DDT liability was on Genpact India, not the assessee Genpact Consulting. The Tribunal rightly concluded that in absence of the AO failing to make requisite inquiry, revision u/s 263 was unjustified. The Revenue failed to establish any additional tax liability on the assessee even if the CIT's view was correct.
The HC held that the CIT's revision order u/s 263 was unsustainable. The CIT's view that the transfer of shares by the assessee was a sham to avoid DDT u/s 115-O was misplaced as the perceived DDT liability was on Genpact India, not the assessee Genpact Consulting. The Tribunal rightly concluded that in absence of the AO failing to make requisite inquiry, revision u/s 263 was unjustified. The Revenue failed to establish any additional tax liability on the assessee even if the CIT's view was correct.
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