Explanation 2 to section 263
WebMay 31, 2024 · The statement to make this election must be titled “Section 1.263 (a)-3 (n) Election” and include the. taxpayer's name, address, taxpayer identification number, and … WebSep 21, 2024 · A. T. Varkey, Judicial Member. – This is an appeal filed by the Assessee against the order of Ld. PCIT, Kolkata-2, Kolkata dated 30-3-2024 passed u/s 263 of Income-tax Act, 1961 (hereinafter referred to as the Act) for Assessment year 2016-17. 2. By preferring this appeal, the assessee has challenged the invocation of jurisdiction by the …
Explanation 2 to section 263
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WebApr 10, 2024 · The PCIT further noted that as per Explanation-2 to Section 263 of the Act, assessment order can be treated as erroneous in so far as it is prejudicial to the interest of the Revenue, if the order is passed without making enquiries or verification which should have been made and the order is passed allowing any relief without inquiring into the ... WebDec 4, 2024 · The amendment to section 263 of the Act by insertion of Explanation 2 to Section 263 of the Act is declaratory & clarificatory in nature and is inserted to provide clarity on the issue as to which orders passed by the AO shall constitute erroneous and prejudicial to the… Westlife Development Ltd vs. Pr. CIT (ITAT Mumbai)
WebJan 5, 2024 · The voluntary exemptions under sections 263A, 448, 460 and 471 generally apply to taxpayers that meet the $25 million (adjusted for inflation) gross receipts test in … WebJan 2, 2024 · Section 263A, often referred to as the Uniform Capitalization rules or UNICAP, requires taxpayers to capitalize direct and indirect costs properly allocable to …
WebJan 11, 2024 · As far as the invocation of Explanation 2 to Section 263 by PCIT in the present case is concerned, we are of the view that only in a very gross case of inadequacy in inquiry or where inquiry is per se mandated on the basis of record available before the AO and such inquiry was not conducted, the revisional power so conferred can be exercised … WebI.R.C. § 263 (g) (2) (A) (i) — interest on indebtedness incurred or continued to purchase or carry the personal property, and I.R.C. § 263 (g) (2) (A) (ii) — all other amounts …
WebJan 29, 2024 · Under section 263 (1) two pre-requisites must be present before the Commissioner can exercise the revisional jurisdiction conferred on him. First is that the order passed by the ITO must be erroneous. Second is that the error must be such that it is prejudicial to the interests of the revenue.
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