Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
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The ITAT held that the assessment order was neither erroneous nor prejudicial to the revenue under section 263, as the AO had duly examined the claim of deduction under Chapter VI-A and adopted a plausible view allowing the entire donation made up to 30.06.2020. The revisionary power under section 263 requires satisfaction of both error and prejudice, which was not established. Regarding CSR expenditure under section 135 of the Companies Act, the tribunal noted that this issue is pending before the jurisdictional High Court and that coordinate benches have favored the assessee's claim of deduction under section 80G, a view the AO rightly followed. Consequently, the PCIT's revision order was set aside, and the appeal filed by the assessee was allowed.
The ITAT held that the assessment order was neither erroneous nor prejudicial to the revenue under section 263, as the AO had duly examined the claim of deduction under Chapter VI-A and adopted a plausible view allowing the entire donation made up to 30.06.2020. The revisionary power under section 263 requires satisfaction of both error and prejudice, which was not established. Regarding CSR expenditure under section 135 of the Companies Act, the tribunal noted that this issue is pending before the jurisdictional High Court and that coordinate benches have favored the assessee's claim of deduction under section 80G, a view the AO rightly followed. Consequently, the PCIT's revision order was set aside, and the appeal filed by the assessee was allowed.
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