Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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ITAT set aside PCIT's revision order under section 263 regarding cooperative society's deduction claim under section 80P(2)(a) and 80P(2)(d) for interest income. The Tribunal held that while AO's order allowing deduction may be prejudicial to revenue interest, it was not erroneous since AO conducted proper inquiry and took plausible view after examining assessee's responses. Following coordinate bench precedent in Talegaon Nagari Sahakari Patsanstha Limited, interest income from deposits with banks qualified for deduction. ITAT emphasized twin conditions for section 263 jurisdiction - order must be both erroneous and prejudicial to revenue. Since AO's decision was reasoned and based on adequate examination, PCIT lacked jurisdiction to revise. Appeal allowed, revision order quashed.
ITAT set aside PCIT's revision order under section 263 regarding cooperative society's deduction claim under section 80P(2)(a) and 80P(2)(d) for interest income. The Tribunal held that while AO's order allowing deduction may be prejudicial to revenue interest, it was not erroneous since AO conducted proper inquiry and took plausible view after examining assessee's responses. Following coordinate bench precedent in Talegaon Nagari Sahakari Patsanstha Limited, interest income from deposits with banks qualified for deduction. ITAT emphasized twin conditions for section 263 jurisdiction - order must be both erroneous and prejudicial to revenue. Since AO's decision was reasoned and based on adequate examination, PCIT lacked jurisdiction to revise. Appeal allowed, revision order quashed.
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