Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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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