Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
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ITAT ruled in favor of the assessee, dismissing PCIT's revision petition under Section 263. The tribunal found that the assessing officer had conducted a comprehensive inquiry during original assessment proceedings, covering 25 detailed points including loan justifications. The key issues of unsecured interest-free loans and potential rental income were thoroughly examined. The tribunal emphasized that when the assessing officer adopts a legally permissible view, and two interpretations are possible, the order cannot be interfered with merely because another perspective exists. The court referenced precedents establishing that 263 proceedings are invalid when the initial assessment included proper enquiries and a plausible legal interpretation. Consequently, the PCIT's order was quashed and the assessee's appeal was allowed.
ITAT ruled in favor of the assessee, dismissing PCIT's revision petition under Section 263. The tribunal found that the assessing officer had conducted a comprehensive inquiry during original assessment proceedings, covering 25 detailed points including loan justifications. The key issues of unsecured interest-free loans and potential rental income were thoroughly examined. The tribunal emphasized that when the assessing officer adopts a legally permissible view, and two interpretations are possible, the order cannot be interfered with merely because another perspective exists. The court referenced precedents establishing that 263 proceedings are invalid when the initial assessment included proper enquiries and a plausible legal interpretation. Consequently, the PCIT's order was quashed and the assessee's appeal was allowed.
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