Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
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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