Please furnish your
explanation to this show cause notice, issued u/s
251(2) of the Act, on 23/12/2011 ... erred
in charging interest u/s 234A , at Rs.31,407/-, u/s 2348 at
RsA8,735/- and u/s 234C
after claiming deduction of Rs.56,58,05,407/-
u/s 80IB of the Act. Subsequently, the assessee company filed its
revised return of income
covered under
the powers of Sec.142A of the Act and this issue is squarely
covered in favour of the assessee and against the Revenue ... Paul vs. CIT (2003) 182 CTR (SC) 489 : (2003) 262
ITR 407 (SC). Sec. 142A , was inserted with
retrospective effect from 15th Nov., 1972, however
covered
under the powers of Sec.142A of the Act and this issue is squarely covered in
favour of the assessee and against the Revenue ... Paul vs. CIT (2003)
182 CTR (SC) 489 : (2003) 262 ITR 407 (SC). Sec. 142A, was
inserted with retrospective effect from 15th Nov., 1972, however
covered
under the powers of Sec.142A of the Act and this issue is squarely covered in
favour of the assessee and against the Revenue ... Paul vs. CIT (2003)
182 CTR (SC) 489 : (2003) 262 ITR 407 (SC). Sec. 142A, was
inserted with retrospective effect from 15th Nov., 1972, however
interest u/s 234D of the Act on the excess
refund issued u/s 143(1).
Initiating penalty proceedings
18. Initiating penalty proceedings ... deduction u/s 10A of the Act to the assessee on enhanced income
as well.
Page 16 of 17
ITA No 407
income from other sources of
Rs.7,01,407). The Return of Income was processed u/s. 143(1) of
the Act and subsequently
pricing adjustment of Rs. 25,10,61,407/-. The above amount
includes interest of about Rs. 5 Crores u/s. 234B and 234C ... 407/- and in the scrutiny assessment, consequent
to the orders of DRP, transfer pricing adjustment of Rs.
25,10,61,407/- was made
submitted, it was only a procedural irregularity which could be cured under Section 292B of the Act. Further, under the doctrine of waiver/ acquiscence, since ... 407 (Lucknow)(SB).
(7) In the case of the present appellant also, notice under Section 158BDwas issued as there was enough material evidence found
assessment order, then,
the Pr. CIT cannot exercise his powers u/sec.263 of the Act.
He has further contended that ... revisional jurisdiction u/ sec.263 of
the Act.
14. In the case of CIT vs. V. Dhana Reddy And Co.
[2018] 407
