Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
The note addresses valuation and disallowance issues: an allotment letter accompanied by part payment through prescribed banking channels can constitute the agreement fixing consideration for comparing actual sale consideration with Stamp Duty Valuation, and the tax authority was directed to verify receipt dates and compare SDV as of allotment; separate disallowances under the rule limiting deduction for exempt-income-related expenditure are unsustainable where no exempt income was earned, and similar 14A additions cannot be made in computing book profit, leading to deletions of those adjustments and remittance of the 43CA factual verification to the assessing officer.
The note addresses valuation and disallowance issues: an allotment letter accompanied by part payment through prescribed banking channels can constitute the agreement fixing consideration for comparing actual sale consideration with Stamp Duty Valuation, and the tax authority was directed to verify receipt dates and compare SDV as of allotment; separate disallowances under the rule limiting deduction for exempt-income-related expenditure are unsustainable where no exempt income was earned, and similar 14A additions cannot be made in computing book profit, leading to deletions of those adjustments and remittance of the 43CA factual verification to the assessing officer.
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