Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
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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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