Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Safe harbour under Rule 11UA(4) was treated as curative and retrospectively applicable: where the difference between issue price and the prescribed valuation did not exceed 10%, the issue price was deemed to be fair market value, so the section 56(2)(viib) addition on shares issued to the resident shareholder could not survive. Legal and professional charges for due diligence, business evaluation and advisory services connected with structuring and growth were held to be revenue expenditure, because no capital asset or enduring capital advantage was shown; the disallowance was deleted.
Safe harbour under Rule 11UA(4) was treated as curative and retrospectively applicable: where the difference between issue price and the prescribed valuation did not exceed 10%, the issue price was deemed to be fair market value, so the section 56(2)(viib) addition on shares issued to the resident shareholder could not survive. Legal and professional charges for due diligence, business evaluation and advisory services connected with structuring and growth were held to be revenue expenditure, because no capital asset or enduring capital advantage was shown; the disallowance was deleted.
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