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...
A composite show cause notice under Section 74 covering multiple tax periods or financial years was held impermissible. The HC relied on its earlier rulings to hold that clubbing distinct tax periods in one proceeding creates a jurisdictional defect, and a notice issued on that basis is illegal. Because the foundational show cause notice was invalid, the consequential Order-in-Original could not survive and was set aside. Liberty was reserved to initiate fresh proceedings in accordance with law, with all contentions kept open.
A composite show cause notice under Section 74 covering multiple tax periods or financial years was held impermissible. The HC relied on its earlier rulings to hold that clubbing distinct tax periods in one proceeding creates a jurisdictional defect, and a notice issued on that basis is illegal. Because the foundational show cause notice was invalid, the consequential Order-in-Original could not survive and was set aside. Liberty was reserved to initiate fresh proceedings in accordance with law, with all contentions kept open.
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