Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Weighted deduction for research and development was confined to expenditure approved by the prescribed authority, but the unapproved revenue outlay retained its character as business expenditure and was allowed under general deduction principles. The Tribunal also applied the presumption that investments were made from interest-free funds where own funds exceeded investments, so the interest component of the exempt-income disallowance was deleted and the balance was to be recomputed only against investments yielding exempt income. Rent paid to related parties for a farmhouse was only partly supported by business use, so the disallowance was restricted to 50%.
Weighted deduction for research and development was confined to expenditure approved by the prescribed authority, but the unapproved revenue outlay retained its character as business expenditure and was allowed under general deduction principles. The Tribunal also applied the presumption that investments were made from interest-free funds where own funds exceeded investments, so the interest component of the exempt-income disallowance was deleted and the balance was to be recomputed only against investments yielding exempt income. Rent paid to related parties for a farmhouse was only partly supported by business use, so the disallowance was restricted to 50%.
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