Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
ITAT upheld the PCIT's revision u/s 263 for AY 2020-21, holding the assessment order erroneous and prejudicial to the interests of Revenue due to non-examination of depreciation claimed on goodwill. The assessee's contention that the tax audit report sufficed and that no further enquiry by AO was needed was rejected. ITAT confined the validity of revision to the year under consideration and held that PCIT's observations regarding earlier years would not bind the set-aside proceedings, though they may guide Revenue separately. The direction to AO to verify the depreciation claim on goodwill was sustained. The objection regarding absence of DIN in the s.263 notice was also rejected.
ITAT upheld the PCIT's revision u/s 263 for AY 2020-21, holding the assessment order erroneous and prejudicial to the interests of Revenue due to non-examination of depreciation claimed on goodwill. The assessee's contention that the tax audit report sufficed and that no further enquiry by AO was needed was rejected. ITAT confined the validity of revision to the year under consideration and held that PCIT's observations regarding earlier years would not bind the set-aside proceedings, though they may guide Revenue separately. The direction to AO to verify the depreciation claim on goodwill was sustained. The objection regarding absence of DIN in the s.263 notice was also rejected.
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