Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
Reopening of assessment under section 147 was invalid where it was based on the same material already examined in the original scrutiny, with no new tangible information, and on an incorrect factual premise that separate research and development accounts were not maintained. The Tribunal treated this as a mere change of opinion after four years and held the jurisdictional assumption bad in law. On merits, it found no multiple deduction: the disputed depreciation was already included in research and development expenditure and had been added back in the income computation, so no further disallowance survived. The appellate authority also could not uphold denial of weighted deduction beyond the reassessment order without enhancement notice.
Reopening of assessment under section 147 was invalid where it was based on the same material already examined in the original scrutiny, with no new tangible information, and on an incorrect factual premise that separate research and development accounts were not maintained. The Tribunal treated this as a mere change of opinion after four years and held the jurisdictional assumption bad in law. On merits, it found no multiple deduction: the disputed depreciation was already included in research and development expenditure and had been added back in the income computation, so no further disallowance survived. The appellate authority also could not uphold denial of weighted deduction beyond the reassessment order without enhancement notice.
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