Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
For assessment orders passed before 1 April 2025, the Assessing Officer lacked jurisdiction to impose or initiate penalty proceedings for contravention of cash loan or deposit restrictions under section 271D. Non-initiation of such penalty proceedings therefore could not make the assessment order erroneous and prejudicial to the interests of the Revenue for revision under section 263. A revisionary order founded solely on that omission was set aside, and the taxpayer's appeal was allowed.
For assessment orders passed before 1 April 2025, the Assessing Officer lacked jurisdiction to impose or initiate penalty proceedings for contravention of cash loan or deposit restrictions under section 271D. Non-initiation of such penalty proceedings therefore could not make the assessment order erroneous and prejudicial to the interests of the Revenue for revision under section 263. A revisionary order founded solely on that omission was set aside, and the taxpayer's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
