Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
Revisionary review under section 263 was considered on whether the AO failed to inquire into the source of share capital and whether acceptance of a merchant banker valuation was erroneous. The tribunal found the AO had the investor's balance sheet before him, accepted the investor's creditworthiness, and that mere suspicion or association with a group did not amount to lack of inquiry. Inquiry into the source-of-source was not required, and the AO properly accepted a DCF valuation by a qualified merchant banker; revisionary interference was unwarranted and decision favoured the assessee.
Revisionary review under section 263 was considered on whether the AO failed to inquire into the source of share capital and whether acceptance of a merchant banker valuation was erroneous. The tribunal found the AO had the investor's balance sheet before him, accepted the investor's creditworthiness, and that mere suspicion or association with a group did not amount to lack of inquiry. Inquiry into the source-of-source was not required, and the AO properly accepted a DCF valuation by a qualified merchant banker; revisionary interference was unwarranted and decision favoured the assessee.
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