Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
ITAT held that a revision under section 263 could not be exercised where the assessment order had been passed in conformity with directions of the DRP, a superior collegial authority. Once the AO gives effect to binding DRP directions and frames the final order accordingly, the Commissioner lacks revisional jurisdiction over that order. On that basis, the section 263 order was quashed for want of jurisdiction, and the remaining grounds were treated as infructuous.
ITAT held that a revision under section 263 could not be exercised where the assessment order had been passed in conformity with directions of the DRP, a superior collegial authority. Once the AO gives effect to binding DRP directions and frames the final order accordingly, the Commissioner lacks revisional jurisdiction over that order. On that basis, the section 263 order was quashed for want of jurisdiction, and the remaining grounds were treated as infructuous.
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