Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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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.
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