Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Extended period of limitation unsustainable; allowable deductions for prompt payment discounts, pro rata recovery, freight and VAT led to demand being...
Revision under section 263 was upheld because the assessing officer failed to verify the assessee's suo motu disallowance of expenditure relating to exempt income and did not test the prescribed computation method or examine a third party report; outcome: revision sustained and relief denied. The tribunal accepted that the AO overlooked available intelligence indicating receipt of accommodation entries, attracting deeming provisions and negating the assessee's claim; outcome: section 263 action valid. The decision relied on precedent on strategic investment exclusion and the duty of the AO to make inquiries, and confirmed the revisional order against the assessee.
Revision under section 263 was upheld because the assessing officer failed to verify the assessee's suo motu disallowance of expenditure relating to exempt income and did not test the prescribed computation method or examine a third party report; outcome: revision sustained and relief denied. The tribunal accepted that the AO overlooked available intelligence indicating receipt of accommodation entries, attracting deeming provisions and negating the assessee's claim; outcome: section 263 action valid. The decision relied on precedent on strategic investment exclusion and the duty of the AO to make inquiries, and confirmed the revisional order against the assessee.
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