Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
Revision under section 263 was denied because the assessing officer adopted a legally permissible view in treating a 5.24% difference between stamp duty value and sale consideration as non-taxable; such a view is not "erroneous and prejudicial to the interests of revenue" and therefore cannot be reopened as a change of opinion. The article holds that statutory tolerance bands introduced by later Finance Acts (5% then 10%) should be given retrospective, beneficial construction to mitigate hardship, and hence the impugned exercise of revisional power was quashed and relief granted to the assessee.
Revision under section 263 was denied because the assessing officer adopted a legally permissible view in treating a 5.24% difference between stamp duty value and sale consideration as non-taxable; such a view is not "erroneous and prejudicial to the interests of revenue" and therefore cannot be reopened as a change of opinion. The article holds that statutory tolerance bands introduced by later Finance Acts (5% then 10%) should be given retrospective, beneficial construction to mitigate hardship, and hence the impugned exercise of revisional power was quashed and relief granted to the assessee.
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