Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
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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