S. 271(1)(c): Penalty-Concealment-Notice-AO had not struck off the inapplicable portion as to whether the levy of penalty was for concealment of income or for furnishing of inaccurate particulars of income-Penalty is not valid.[S.274]
S. 271(1)(c): Penalty-Concealment-Notice-AO had not struck off the inapplicable portion as to whether the levy of penalty was for concealment of income or for furnishing of inaccurate particulars of income-Penalty is not valid.[S.274]
S. 271(1)(c): Penalty-Concealment-The assessee has neither concealed the particulars of the income nor furnished such facts which lead to the furnishing of inaccurate particulars.
S.263: Commissioner-Revision of orders prejudicial to revenue-Not for corrections, errors & mistake-No order in existence.[S.271(1)(c), 271AAB(IA)]
S. 263: Commissioner-Revision of orders prejudicial to revenue-Duly examined matter on mere surmise of human probability. [S. 142(1), 143(2), 143(3)]
S. 263: Commissioner-Revision of orders prejudicial to revenue-Assessment order which is nullity in law-Cannot be revised. [S.132A, 143(3)]
S. 263: Commissioner-Revision of orders prejudicial to revenue-Principal commissioner is not justified in initiating revision proceedings when proceedings have already declared under the Direct Tax Vivad Se Vishwas Scheme. [Direct Tax Vivad Se Vishwas Act, 2020, S. 8]
S. 263: Commissioner-Revision of orders prejudicial to revenue-commissioner taking view explanation offered by the assessee to assessing officer not satisfactory and assessing officer had failed to conduct further enquiries, revision based on audit objection is invalid. [S. 68, 69, 69A, 69B, 69C, 69D, 115BBE]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-AO allowed deduction u/s 35(2AB) after verifying all the necessary documents and certificates-Neither the AO nor the PCIT has power to question the approval granted by the DSIR. [S. 35(2AB), 143(3)]
S. 263: Commissioner-Revision of orders prejudicial to revenue-No detailed inquiry or verification by PCIT-Failure to point out error in assessment order-Order is quashed. [S.35(2AB), 143(3)]
S.263: Commissioner-Revision of orders prejudicial to revenue-Since the revisionary order was passed within five days from the date of issuance of show cause notice, proper and effective opportunity of being heard was not provided to the assessee matter restored back to PCIT to pass fresh revisionary order after giving proper and adequate opportunity of being heard to the assessee.[S.143(3)]