Revision u/s 263 - Transfer pricing (TP) adjustments - passing ...

Section 263 Revision Invalidated: Original Assessment Order Deemed Void Due to Timing Issues u/ss 143(3) and 153(1).

December 6, 2019

Case Laws Income Tax AT

Revision u/s 263 - Transfer pricing (TP) adjustments - passing an order u/s 143(3) r.w.s 144C after the prescribed time limit u/s 153(1) r.w.s 92CA - When the original Assessment Order passed u/s. 143 (3) of the Act was null and void in the eyes of law, the Commissioner could not have assumed jurisdiction under law to make revision of a non-est order

View Source

← Previous Next →

Revision u/s 263 - Transfer pricing (TP) adjustments - passing ...

Section 263 Revision Invalidated: Original Assessment Order Deemed Void Due to Timing Issues u/ss 143(3) and 153(1).

December 6, 2019

Case Laws Income Tax AT

You may also like:

The Rajasthan High Court examined the validity of revision proceedings u/s 263 concerning the period of limitation. The issue was whether the period of limitation for...

Revision u/s 263 - Being conscious of the fact that the original assessment order could not be revised under section 263 of the Act due to bar of limitation, as provided...

Revision u/s 263 - Period of limitation - To be commenced from original assessment order or re-assessment order u/s 147 - In the case on hand, the jurisdiction under...

Revision u/s 263 - Invocation of revision proceedings for the second time - As pertinent to point out that there was no bar on limitation by the ld. PCIT to invoke...

Revision u/s 263 - When the ld. Commissioner issued a show cause notice under section 263 and ultimately passed impugned order; by that time the alleged domestic...

ITAT ruled against Principal CIT's revision under Section 263, finding the order procedurally flawed. The tribunal held that PCIT cannot delegate verification...

Revision u/s 263 based on DVO's report received after assessment culmination was invalid as per section 142A(4), DVO failed to provide opportunity of being heard to...

Revision u/s 263 - at the time of exercise of jurisdiction under Section 263, admittedly, proceedings before AAR was pending on the issue of taxability of receipts from...

Power of revision under section 263 – Amendment to Explanation to Section 115 JB - subsequent amendment in 2005 even though retrospective will not attract the provision...

Revision u/s 263 - order has been passed by the Ld. CIT under section 263 without considering the explanation offered by the assessee and without applying his mind. In...

Validity of revision proceedings u/s 263 - Adoption of either of view by AO - allowability under section 36(1)(viia) - The court concludes that the original assessment...

Revision u/s 263 - PCIT issued the above show cause notice u/s 263 in respect of specified domestic transactions referred to in clause (i) of section 92BA of the Act...

Revision u/s 263 - CIT setting aside the second reassessment order - time limit to take action u/s 263 - the necessity for the Commissioner to have substantial grounds...

Revision u/s 263 - Explanation 2(d) under section 263 specifically states that revision is possible only due to judgments of the jurisdictional High Court or supreme...

Revision u/s 263 - the ld PCIT had invoked revision jurisdiction u/s 263 of the Act on the very same point of allowability of LTCL. Hence it could be safely concluded...

Quick Updates: