Fraudulent trading requires cogent evidence of intent to defraud; ordinary-course payments protected, except post-insolvency withdrawals must be resto...
Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Page of 4830
Press 'Enter' after typing page number.
6061 to 6080 of 96587 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Revisional jurisdiction under s.263 was invoked on the premise that the reassessment was erroneous and prejudicial because the AO allegedly failed to consider an order under s.92CA(3) and verify the arm's length price of royalty. Since no s.92CA(3) order was ever passed, the alleged error was legally untenable, and the AO, having made a reference, could not himself substitute the TPO's specialized determination, consistent with s.92CA(4) ("if any"). Further, s.263 could not be used to compel a fresh ALP determination after the TPO's power stood exhausted by limitation under s.92CA(3A). The revision was quashed and the assessee's appeal allowed - ITAT
Revisional jurisdiction under s.263 was invoked on the premise that the reassessment was erroneous and prejudicial because the AO allegedly failed to consider an order under s.92CA(3) and verify the arm's length price of royalty. Since no s.92CA(3) order was ever passed, the alleged error was legally untenable, and the AO, having made a reference, could not himself substitute the TPO's specialized determination, consistent with s.92CA(4) ("if any"). Further, s.263 could not be used to compel a fresh ALP determination after the TPO's power stood exhausted by limitation under s.92CA(3A). The revision was quashed and the assessee's appeal allowed - ITAT
Note: It is a system-generated summary and is for quick reference only.