Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
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...
Revisionary power under section 263 was examined in relation to a disallowance under section 11 for payments to specified/related persons; ITAT held the revisional authority failed to conduct its own enquiry and improperly remanded the matter for fresh verification, which constitutes an impermissible roving inquiry. The Assessing Officer had sought and considered detailed explanations and documents from the assessee before passing the assessment, and no material demonstrated falsity or discrepancy. Because no prejudice to revenue arose (taxes paid by specified persons and no taxable income in trust), the CIT(E)'s revision was set aside and the assessee's grounds allowed.
Revisionary power under section 263 was examined in relation to a disallowance under section 11 for payments to specified/related persons; ITAT held the revisional authority failed to conduct its own enquiry and improperly remanded the matter for fresh verification, which constitutes an impermissible roving inquiry. The Assessing Officer had sought and considered detailed explanations and documents from the assessee before passing the assessment, and no material demonstrated falsity or discrepancy. Because no prejudice to revenue arose (taxes paid by specified persons and no taxable income in trust), the CIT(E)'s revision was set aside and the assessee's grounds allowed.
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