Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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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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