Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
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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