Customs Valuation Rule Sequence must be followed; single-comparator re-determination and penalties set aside without comparability or proof of mis-dec...
Separately Identifiable Services: transportation found to be the essential character, so Cargo Handling classification and extended limitation rejecte...
Revision proceedings under section 263 were held impermissible because the Assessing Officer conducted due enquiries and took a plausible view in restricting a deduction claimed under section 80P(2)(d) to profits from credit facilities to members. The AO verified accounts, investments and supporting details and disallowed the portion of the claim after application of mind; the superior officer's disagreement alone did not satisfy the twin conditions required to invoke revision u/s 263. Result: revision power not exercisable and the AO's assessment view is sustained in favour of the assessee.
Revision proceedings under section 263 were held impermissible because the Assessing Officer conducted due enquiries and took a plausible view in restricting a deduction claimed under section 80P(2)(d) to profits from credit facilities to members. The AO verified accounts, investments and supporting details and disallowed the portion of the claim after application of mind; the superior officer's disagreement alone did not satisfy the twin conditions required to invoke revision u/s 263. Result: revision power not exercisable and the AO's assessment view is sustained in favour of the assessee.
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