Condonation of delay in filing GSTR-3B returns and entitlement to Section 62 benefit results in withdrawal of assessments and revocation of attachment...
Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
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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