Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
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Revision under Section 263 was sustained because the appellate merger doctrine applied only to matters actually considered by the CIT(A), and the separate issue of apportioning common Head Office expenses for the Section 80-IA deduction had not been examined. The Court held that transfer pricing proceedings under Section 92CA addressed arm's length price, not the full computation of eligible profits, so the Assessing Officer retained a duty to verify overhead allocation. It also held that a plausible view requires actual inquiry, and the absence of inquiry made the assessment erroneous and prejudicial. For the abated search year, the absence of seized material did not bar scrutiny, and the appeals were dismissed.
Revision under Section 263 was sustained because the appellate merger doctrine applied only to matters actually considered by the CIT(A), and the separate issue of apportioning common Head Office expenses for the Section 80-IA deduction had not been examined. The Court held that transfer pricing proceedings under Section 92CA addressed arm's length price, not the full computation of eligible profits, so the Assessing Officer retained a duty to verify overhead allocation. It also held that a plausible view requires actual inquiry, and the absence of inquiry made the assessment erroneous and prejudicial. For the abated search year, the absence of seized material did not bar scrutiny, and the appeals were dismissed.
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