Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
The High Court noted that the Supreme Court, in identical reassessment matters, had set aside earlier quashing orders and remitted the cases for fresh consideration while keeping all merits issues open. In light of that binding development, the Court declined to examine the controversy on merits, set aside the Single Judge's order, and remitted the matter for reconsideration with all contentions preserved. The Court also granted the assessee liberty to challenge newly inserted section 147A and any connected or consequential provisions, consistent with the Supreme Court's permission in similar matters, and allowed the Revenue to file further affidavit or submissions.
The High Court noted that the Supreme Court, in identical reassessment matters, had set aside earlier quashing orders and remitted the cases for fresh consideration while keeping all merits issues open. In light of that binding development, the Court declined to examine the controversy on merits, set aside the Single Judge's order, and remitted the matter for reconsideration with all contentions preserved. The Court also granted the assessee liberty to challenge newly inserted section 147A and any connected or consequential provisions, consistent with the Supreme Court's permission in similar matters, and allowed the Revenue to file further affidavit or submissions.
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