Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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Revision under section 263 was scrutinised on whether the AO made no inquiry or an inadequate inquiry regarding additions under scrutiny. The tribunal found the AO had conducted detailed investigation and enquiries before making additions; therefore the revisional authority's exercise amounted to a change of opinion and was not permissible. Explanation 2 was held inapplicable because the assessment was not passed without any inquiry. The issue was also treated as debatable in view of a coordinate bench decision deleting comparable additions. Consequence: the revision was set aside and the assessee's appeal was allowed.
Revision under section 263 was scrutinised on whether the AO made no inquiry or an inadequate inquiry regarding additions under scrutiny. The tribunal found the AO had conducted detailed investigation and enquiries before making additions; therefore the revisional authority's exercise amounted to a change of opinion and was not permissible. Explanation 2 was held inapplicable because the assessment was not passed without any inquiry. The issue was also treated as debatable in view of a coordinate bench decision deleting comparable additions. Consequence: the revision was set aside and the assessee's appeal was allowed.
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