Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
ITAT held that revision under section 263 was not justified because the AO had made adequate enquiry on cash sales, cash deposits, opening stock and purchases, and the assessee had furnished replies and records during assessment. The Tribunal found no lack of enquiry and held that the Principal Commissioner could not invoke revision merely to substitute a different view on the same material. Applying the principle that section 263 requires both error and prejudice to revenue, and that revision is unavailable where two plausible views exist, the Tribunal quashed the revisionary orders and allowed all three appeals.
ITAT held that revision under section 263 was not justified because the AO had made adequate enquiry on cash sales, cash deposits, opening stock and purchases, and the assessee had furnished replies and records during assessment. The Tribunal found no lack of enquiry and held that the Principal Commissioner could not invoke revision merely to substitute a different view on the same material. Applying the principle that section 263 requires both error and prejudice to revenue, and that revision is unavailable where two plausible views exist, the Tribunal quashed the revisionary orders and allowed all three appeals.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
