Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
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Revision under section 263 was unwarranted where the Assessing Officer had examined the assessee's accumulation claim, Form No. 10, board resolutions and utilisation particulars, and had adopted a possible view on the material before him. The Commissioner could not invoke revision merely because he wanted deeper verification or considered another view preferable; absent independent demonstration that the assessment order was erroneous and prejudicial to revenue, the exercise amounted to an impermissible fishing enquiry. The Court also held that Explanation 2 to section 263 could not be applied without prior notice to the assessee. The alleged tax consequence of non-utilisation of accumulated income did not arise in the relevant assessment year.
Revision under section 263 was unwarranted where the Assessing Officer had examined the assessee's accumulation claim, Form No. 10, board resolutions and utilisation particulars, and had adopted a possible view on the material before him. The Commissioner could not invoke revision merely because he wanted deeper verification or considered another view preferable; absent independent demonstration that the assessment order was erroneous and prejudicial to revenue, the exercise amounted to an impermissible fishing enquiry. The Court also held that Explanation 2 to section 263 could not be applied without prior notice to the assessee. The alleged tax consequence of non-utilisation of accumulated income did not arise in the relevant assessment year.
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