Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
ITAT allowed the appeal and set aside the s.263 revision order of the PCIT. The Tribunal held that Explanation 2 to s.263(1) was invoked by the PCIT in the final order without being specified in the show-cause notice or affording the assessee an opportunity to meet that specific contention, thereby violating principles of natural justice. In consequence, the invocation of Explanation 2 was unsustainable and rendered the revision order prejudicial and void. The s.263 order was quashed and the grounds of the assessee upheld, restoring the original reassessment outcome.
ITAT allowed the appeal and set aside the s.263 revision order of the PCIT. The Tribunal held that Explanation 2 to s.263(1) was invoked by the PCIT in the final order without being specified in the show-cause notice or affording the assessee an opportunity to meet that specific contention, thereby violating principles of natural justice. In consequence, the invocation of Explanation 2 was unsustainable and rendered the revision order prejudicial and void. The s.263 order was quashed and the grounds of the assessee upheld, restoring the original reassessment outcome.
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