Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
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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