Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Revisional powers under Section 264 were held to be broad and aimed at preventing miscarriage of justice and granting relief to an assessee even where the assessee committed mistakes in the original return; consequently the revision application should have been considered and the impugned order under Section 264 was set aside. The court distinguished the Supreme Court decision in Goetze (India) Ltd., finding it inapplicable because that case did not address revisional powers under Section 264 but concerned a post filing deduction without a revised return.
Revisional powers under Section 264 were held to be broad and aimed at preventing miscarriage of justice and granting relief to an assessee even where the assessee committed mistakes in the original return; consequently the revision application should have been considered and the impugned order under Section 264 was set aside. The court distinguished the Supreme Court decision in Goetze (India) Ltd., finding it inapplicable because that case did not address revisional powers under Section 264 but concerned a post filing deduction without a revised return.
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