CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits po...
Scope of judicial review under Article 226: supervisory, not appellate; factual reappraisal barred, challenge dismissed; insolvency professional dutie...
Courier transshipment of imported goods via named carrier to air cargo stations renewed until 30.01.2026; exemption conditional, strict controls apply...
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.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
