Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
ITAT held that the revision order u/s 263 was invalid. The AO conducted a comprehensive search assessment u/s 153A, thoroughly examining seized materials and assessee's sworn statements. The tribunal found no procedural error or prejudice to revenue's interests, as the assessee had transparently declared and paid taxes on anonymous and corpus donations. The assessment was based on complete verification of facts, and the AO took a plausible view. The tribunal specifically noted that retrospective application of subsequent judicial precedents was impermissible. Consequently, the ITAT quashed the revision order passed by PCIT and allowed the assessee's appeal, affirming the original search assessment order.
ITAT held that the revision order u/s 263 was invalid. The AO conducted a comprehensive search assessment u/s 153A, thoroughly examining seized materials and assessee's sworn statements. The tribunal found no procedural error or prejudice to revenue's interests, as the assessee had transparently declared and paid taxes on anonymous and corpus donations. The assessment was based on complete verification of facts, and the AO took a plausible view. The tribunal specifically noted that retrospective application of subsequent judicial precedents was impermissible. Consequently, the ITAT quashed the revision order passed by PCIT and allowed the assessee's appeal, affirming the original search assessment order.
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