Refund claim dismissed as time-barred under s.142(5); non-obstante clause read restrictively, merits not decided, self-assessment payments not mere de...
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ITAT allowed the appeal, holding the PCIT's revision under s.263 invalid and quashing the s.263 order. The Tribunal found the AO had conducted requisite enquiries during the s.143(3) assessment, considered documentary evidence and law, and legitimately accepted the assessee's claim regarding payments to foreign agents and non-applicability of s.195 r.w.s.9. The prerequisites for invoking s.263-an order both erroneous and prejudicial to revenue-were not satisfied, and the show-cause notice lacked particulars and denied the assessee an opportunity on the verification direction, vitiating the proceedings. Consequently the direction to annul the assessment and reframe it was held bad in law.
ITAT allowed the appeal, holding the PCIT's revision under s.263 invalid and quashing the s.263 order. The Tribunal found the AO had conducted requisite enquiries during the s.143(3) assessment, considered documentary evidence and law, and legitimately accepted the assessee's claim regarding payments to foreign agents and non-applicability of s.195 r.w.s.9. The prerequisites for invoking s.263-an order both erroneous and prejudicial to revenue-were not satisfied, and the show-cause notice lacked particulars and denied the assessee an opportunity on the verification direction, vitiating the proceedings. Consequently the direction to annul the assessment and reframe it was held bad in law.
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