Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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