Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Revision under section 263 was examined on whether the AO failed to make requisite enquiries or made inadequate enquiries; the tribunal found the AO had verified seized materials, recorded the assessee's statement and considered explanations, so the basis for revisional jurisdiction was absent and the PCIT's order could not be sustained. The requirement that a revisional order be founded on objective material and specific findings, not mere subjective dissatisfaction or the brevity of the AO's order, was emphasized; consequently the revisional action was quashed and the appeal allowed.
Revision under section 263 was examined on whether the AO failed to make requisite enquiries or made inadequate enquiries; the tribunal found the AO had verified seized materials, recorded the assessee's statement and considered explanations, so the basis for revisional jurisdiction was absent and the PCIT's order could not be sustained. The requirement that a revisional order be founded on objective material and specific findings, not mere subjective dissatisfaction or the brevity of the AO's order, was emphasized; consequently the revisional action was quashed and the appeal allowed.
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