Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Ad hoc restriction of employee benefit expenditure requires reconciliation of salary details, vouchers, service evidence and business nexus, rather than comparison with revenue alone. Share premium additions turn on substantiation of fair market value under the valuation framework, and an incorrect statutory label does not displace the substance of the addition where no valuation report is produced. ESOP discount is recognised as employee compensation and potentially allowable as business expenditure, but the claim must be supported by valuation and grant-wise working. Loss on sale of subsidiary investment may be treated as business loss only where commercial expediency is established, and additional evidence must comply with Rule 46A and natural justice.
Ad hoc restriction of employee benefit expenditure requires reconciliation of salary details, vouchers, service evidence and business nexus, rather than comparison with revenue alone. Share premium additions turn on substantiation of fair market value under the valuation framework, and an incorrect statutory label does not displace the substance of the addition where no valuation report is produced. ESOP discount is recognised as employee compensation and potentially allowable as business expenditure, but the claim must be supported by valuation and grant-wise working. Loss on sale of subsidiary investment may be treated as business loss only where commercial expediency is established, and additional evidence must comply with Rule 46A and natural justice.
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