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...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Section 270AA gives finality where an assessee accepts the assessment without appeal and secures immunity from penalty and prosecution; a later section 154 rectification cannot be used to substantially rewrite the assessment or change its tax consequence, so the rectification order was without jurisdiction. An ad hoc disallowance of expenditure already recorded in the books and reflected in the accounts is not unexplained expenditure under section 69C; it is only an estimated disallowance for want of verification, so section 115BBE could not be applied in rectification proceedings. The Tribunal quashed both the rectification order and the appellate order affirming it.
Section 270AA gives finality where an assessee accepts the assessment without appeal and secures immunity from penalty and prosecution; a later section 154 rectification cannot be used to substantially rewrite the assessment or change its tax consequence, so the rectification order was without jurisdiction. An ad hoc disallowance of expenditure already recorded in the books and reflected in the accounts is not unexplained expenditure under section 69C; it is only an estimated disallowance for want of verification, so section 115BBE could not be applied in rectification proceedings. The Tribunal quashed both the rectification order and the appellate order affirming it.
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