Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
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ITAT quashed PCIT's revision order u/s 263 challenging validity of reassessment proceedings u/s 153A regarding computation of total income claiming interest u/s 24B. Tribunal held that Explanation 2 invoked by PCIT had no application as all relevant documents were filed by assessee during reassessment proceedings, which AO verified before finalizing assessment allowing interest claim u/s 24B. ITAT noted AO had previously allowed similar interest claim in AY 2012-13, establishing continuing cause of action that cannot be disturbed without different factual findings. Tribunal found PCIT's order reflected non-application of mind since AO had conducted adequate inquiries and examination of assessee's claims during both original and reassessment proceedings u/s 153A, taking plausible view not prejudicial to Revenue interests. Appeal allowed.
ITAT quashed PCIT's revision order u/s 263 challenging validity of reassessment proceedings u/s 153A regarding computation of total income claiming interest u/s 24B. Tribunal held that Explanation 2 invoked by PCIT had no application as all relevant documents were filed by assessee during reassessment proceedings, which AO verified before finalizing assessment allowing interest claim u/s 24B. ITAT noted AO had previously allowed similar interest claim in AY 2012-13, establishing continuing cause of action that cannot be disturbed without different factual findings. Tribunal found PCIT's order reflected non-application of mind since AO had conducted adequate inquiries and examination of assessee's claims during both original and reassessment proceedings u/s 153A, taking plausible view not prejudicial to Revenue interests. Appeal allowed.
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