Courier transshipment of imported goods via named carrier to air cargo stations renewed until 30.01.2026; exemption conditional, strict controls apply...
Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quash...
The dominant issue was whether revision under s.263 could be sustained on the premise that carry forward of unabsorbed depreciation and business losses was wrongly allowed due to non-fulfilment of the three-year existence condition in s.72A(2). The court held that s.72A(4), applicable to a demerger, contains no such condition, and the record showed the authority was aware of the assessee's reliance on this distinction. As the revisional authority neither identified a concrete error in the assessment nor articulated any specific doubt despite available scheme orders, the s.263 direction was held to be a roving enquiry and invalid; questions were answered in favour of the assessee. - HC
The dominant issue was whether revision under s.263 could be sustained on the premise that carry forward of unabsorbed depreciation and business losses was wrongly allowed due to non-fulfilment of the three-year existence condition in s.72A(2). The court held that s.72A(4), applicable to a demerger, contains no such condition, and the record showed the authority was aware of the assessee's reliance on this distinction. As the revisional authority neither identified a concrete error in the assessment nor articulated any specific doubt despite available scheme orders, the s.263 direction was held to be a roving enquiry and invalid; questions were answered in favour of the assessee. - HC
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