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...
An addition for unexplained investment cannot be sustained unless the investment was made in the financial year immediately preceding the relevant assessment year. Here, the ledger accounts and year-wise expenditure charts showed that the opening work-in-progress consisted of expenditure incurred over several earlier years, and the Revenue itself treated it as a prior-period balance. The Assessing Officer could not tax that historical investment in the current year merely because earlier returns were filed on a non-business basis or because prior disclosure was allegedly incomplete. The addition under Section 69 was therefore unsustainable and was deleted.
An addition for unexplained investment cannot be sustained unless the investment was made in the financial year immediately preceding the relevant assessment year. Here, the ledger accounts and year-wise expenditure charts showed that the opening work-in-progress consisted of expenditure incurred over several earlier years, and the Revenue itself treated it as a prior-period balance. The Assessing Officer could not tax that historical investment in the current year merely because earlier returns were filed on a non-business basis or because prior disclosure was allegedly incomplete. The addition under Section 69 was therefore unsustainable and was deleted.
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