Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT set aside the revision order passed by PCIT under section 263, holding it to be beyond the scope of a limited scrutiny assessment. The AO had issued notice under section 142(1) for limited scrutiny and the assessee furnished requisite details; alleged failures to verify salary income and to disallow amounts under section 14A read with Rule 8D fall outside the permissible ambit of limited scrutiny. PCIT could not validly initiate revision on issues requiring complete scrutiny without obtaining prior sanction from the CIT. The Tribunal quashed the impugned revision as unauthorized and procedurally infirm for exceeding the limited scrutiny mandate.
ITAT set aside the revision order passed by PCIT under section 263, holding it to be beyond the scope of a limited scrutiny assessment. The AO had issued notice under section 142(1) for limited scrutiny and the assessee furnished requisite details; alleged failures to verify salary income and to disallow amounts under section 14A read with Rule 8D fall outside the permissible ambit of limited scrutiny. PCIT could not validly initiate revision on issues requiring complete scrutiny without obtaining prior sanction from the CIT. The Tribunal quashed the impugned revision as unauthorized and procedurally infirm for exceeding the limited scrutiny mandate.
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