Circular No. 15 of 2015 — the law in short
What the courts have decided on section Circular No. 15 of 2015, in one screen. Read this first; open an entry when you need the facts, the reasoning and the source.
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Chintan Navnitlal Parikh v PDIT (Inv)
ITATHelps taxpayerNo later treatment found
I declared my interest in a foreign discretionary trust under s.59 and the assessment accepted it. Can the Principal Director now revise that order?
Not where the point was examined at the assessment stage. The Tribunal set aside a revision under s.23 of the Black Money Act, holding that an order passed after due enquiry and verification is neither erroneous nor prejudicial to the interest of the Revenue within s.23(2) and cannot be called prejudicial under s.23(9). It also records the valuation route for a beneficiary's interest in a foreign trust: the trust's assets are valued as an association of persons under Rule 3(1)(g), with the shares held by the trust valued first under Rule 3(1)(c).
Listed strongest first: Supreme Court, then High Court, then Tribunal, then CBDT. Nothing here has yet been read in full by a chartered accountant — open an entry to see where it came from.
