Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Interest income under the mercantile system was held taxable in AY 2007-08 on accrual basis because the assessee, having followed that method, had to bring the entire accrued amount to tax in that year and produced no corroborative material showing that accrual had been deferred by litigation or other valid reason. The Tribunal also upheld reopening under section 147, holding that the original assessment had not examined the balance accrued interest and that information from remand proceedings constituted tangible material; the plea of mere change of opinion therefore failed. To avoid double taxation, it approved verification and rectification in AY 2009-10 if the amount had been declared there.
Interest income under the mercantile system was held taxable in AY 2007-08 on accrual basis because the assessee, having followed that method, had to bring the entire accrued amount to tax in that year and produced no corroborative material showing that accrual had been deferred by litigation or other valid reason. The Tribunal also upheld reopening under section 147, holding that the original assessment had not examined the balance accrued interest and that information from remand proceedings constituted tangible material; the plea of mere change of opinion therefore failed. To avoid double taxation, it approved verification and rectification in AY 2009-10 if the amount had been declared there.
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