Appeal allows marketing payments as deductible business expenses under Sec.37; director pay retained; R&D deductible from certificate date under Sec.3...
Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
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ITAT held that the revisionary orders passed by PCIT under s.263 were ultravires and unsustainable. The Tribunal found that the AO, in assessments framed under s.153A, did not make additions based on any incriminating material seized in the search, nor did the PCIT's s.263 order record reliance on such material. The PCIT's examination of the assessee's entitlement to deduction under s.80IC went beyond the scope of the s.153A assessment and thus outside the jurisdictional ambit of s.263. Consequently, the s.263 order was quashed as erroneous for lack of statutory mandate; the Tribunal did not adjudicate on the substantive merits of the s.80IC claim.
ITAT held that the revisionary orders passed by PCIT under s.263 were ultravires and unsustainable. The Tribunal found that the AO, in assessments framed under s.153A, did not make additions based on any incriminating material seized in the search, nor did the PCIT's s.263 order record reliance on such material. The PCIT's examination of the assessee's entitlement to deduction under s.80IC went beyond the scope of the s.153A assessment and thus outside the jurisdictional ambit of s.263. Consequently, the s.263 order was quashed as erroneous for lack of statutory mandate; the Tribunal did not adjudicate on the substantive merits of the s.80IC claim.
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