Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
ITAT held that revision under section 263 was unsustainable because the DPCO liability for the relevant year had already been treated as an ascertained liability, and the Assessing Officer's acceptance of that position was a plausible view. The revisional authority proceeded on an factual premise, assuming the DPCO dispute had been settled by the Supreme Court and treating the amounts as bank guarantees, whereas the dispute remained pending before the High Court and the Supreme Court proceeding concerned a different matter. As the assessment order was neither erroneous nor prejudicial to the interests of the Revenue, the revisional order was set aside and the assessee's appeal was allowed.
ITAT held that revision under section 263 was unsustainable because the DPCO liability for the relevant year had already been treated as an ascertained liability, and the Assessing Officer's acceptance of that position was a plausible view. The revisional authority proceeded on an factual premise, assuming the DPCO dispute had been settled by the Supreme Court and treating the amounts as bank guarantees, whereas the dispute remained pending before the High Court and the Supreme Court proceeding concerned a different matter. As the assessment order was neither erroneous nor prejudicial to the interests of the Revenue, the revisional order was set aside and the assessee's appeal was allowed.
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