Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Issue: Whether a Revisional order under section 263 can direct initiation of penalty under section 271E absent the Assessing Officer's satisfaction in the assessment order. Reasoning: Relying on the Supreme Court principle that initiation/levy of penalty under s.271E requires satisfaction recorded in the assessment, the Revisional Authority erred in treating penalty initiation as independent of AO's satisfaction and in distinguishing earlier High Court precedent. Outcome: The section 263 order directing initiation of penalty under s.271E was unsustainable and is set aside; appeal allowed. - ITAT
Issue: Whether a Revisional order under section 263 can direct initiation of penalty under section 271E absent the Assessing Officer's satisfaction in the assessment order. Reasoning: Relying on the Supreme Court principle that initiation/levy of penalty under s.271E requires satisfaction recorded in the assessment, the Revisional Authority erred in treating penalty initiation as independent of AO's satisfaction and in distinguishing earlier High Court precedent. Outcome: The section 263 order directing initiation of penalty under s.271E was unsustainable and is set aside; appeal allowed. - ITAT
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TaxTMI 
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