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...
Explanation 4 to section 11 prevents loan-funded expenditure from being treated as application of income when the borrowing is deployed, but permits the repayment to qualify in the year of repayment if that amount was not already allowed. On the record, the charitable trust had excluded borrowed sums from application in the years of borrowing and claimed application only on repayment, and the Revenue did not rebut the supporting accounts, returns or statements. As no earlier double claim was shown, the repayment was treated as valid application of income and the disallowance was deleted.
Explanation 4 to section 11 prevents loan-funded expenditure from being treated as application of income when the borrowing is deployed, but permits the repayment to qualify in the year of repayment if that amount was not already allowed. On the record, the charitable trust had excluded borrowed sums from application in the years of borrowing and claimed application only on repayment, and the Revenue did not rebut the supporting accounts, returns or statements. As no earlier double claim was shown, the repayment was treated as valid application of income and the disallowance was deleted.
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