International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
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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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