Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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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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