Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Section 263 revision cannot be invoked solely because the Assessing Officer did not initiate penalty proceedings under section 270A. Penalty proceedings are independent of assessment proceedings, so a failure to record an opinion on penalty liability does not make the assessment order erroneous and prejudicial to the interests of the Revenue. Revisional jurisdiction therefore cannot be used to direct initiation of penalty proceedings, including under a different penalty provision. The revision order was quashed and the assessee's appeal was allowed.
Section 263 revision cannot be invoked solely because the Assessing Officer did not initiate penalty proceedings under section 270A. Penalty proceedings are independent of assessment proceedings, so a failure to record an opinion on penalty liability does not make the assessment order erroneous and prejudicial to the interests of the Revenue. Revisional jurisdiction therefore cannot be used to direct initiation of penalty proceedings, including under a different penalty provision. The revision order was quashed and the assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
