Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
The text addresses revision jurisdiction over income-tax assessments concerning professional and technical fees, sundry creditors, notional interest under Ind AS, and stock valuation. On the alleged difference for professional and technical fees, the record shows AO queries, assessee replies and supporting documents, therefore the revisional finding was contrary to record and unsustainable. On addition of sundry creditors, a debit (trade receivable) was shown and incorporated in P&L, so the revisional addition was factually incorrect and unsustainable. On notional interest, reconciliation with Form 26AS and balance sheet showed no variation, so the revisional action was unwarranted. On stock valuation, AO failed adequate inquiry into valuation method and consistency, so the revisional concern is upheld.
The text addresses revision jurisdiction over income-tax assessments concerning professional and technical fees, sundry creditors, notional interest under Ind AS, and stock valuation. On the alleged difference for professional and technical fees, the record shows AO queries, assessee replies and supporting documents, therefore the revisional finding was contrary to record and unsustainable. On addition of sundry creditors, a debit (trade receivable) was shown and incorporated in P&L, so the revisional addition was factually incorrect and unsustainable. On notional interest, reconciliation with Form 26AS and balance sheet showed no variation, so the revisional action was unwarranted. On stock valuation, AO failed adequate inquiry into valuation method and consistency, so the revisional concern is upheld.
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