Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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The determinative issue was whether the Assessing Officer had made the enquiry required before the Principal Commissioner invoked revision under section 263. The High Court treated that enquiry question as a pure question of fact, and held that the Tribunal's finding on it could not be converted into a substantial question of law under section 260A. As the Revenue's challenge depended on whether assessment proceedings were conducted with or without enquiry, the appeal was not entertainable on the basis urged and was rejected.
The determinative issue was whether the Assessing Officer had made the enquiry required before the Principal Commissioner invoked revision under section 263. The High Court treated that enquiry question as a pure question of fact, and held that the Tribunal's finding on it could not be converted into a substantial question of law under section 260A. As the Revenue's challenge depended on whether assessment proceedings were conducted with or without enquiry, the appeal was not entertainable on the basis urged and was rejected.
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