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...
Revision under Section 263 was held vitiated where the revisional opinion reallocating R&D expenditure to eligible undertakings rested on presumption and conjecture rather than concrete evidence; the Assessing Officer had conducted a full enquiry and permissibly allowed the R&D deduction. The Tribunal found the revisionary exercise to be materially influenced by an audit objection and not an independent satisfaction, quashed the revision order and restored the assessment order of the AO, allowing the assessee's appeal.
Revision under Section 263 was held vitiated where the revisional opinion reallocating R&D expenditure to eligible undertakings rested on presumption and conjecture rather than concrete evidence; the Assessing Officer had conducted a full enquiry and permissibly allowed the R&D deduction. The Tribunal found the revisionary exercise to be materially influenced by an audit objection and not an independent satisfaction, quashed the revision order and restored the assessment order of the AO, allowing the assessee's appeal.
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