Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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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