Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Reopening under section 147 was held invalid where recomputation of depreciation would not alter the assessee's tax liability under the MAT regime. The infrastructure business was already entitled to full deduction on profits, and any higher depreciation rate would only reduce normal income without affecting the book profit taxed under section 115JB. Because the depreciation particulars were already disclosed in the original scrutiny assessment, the attempt to reopen on the same material amounted to a mere change of opinion. The notice and reassessment order were quashed for want of any escapement of income chargeable to tax.
Reopening under section 147 was held invalid where recomputation of depreciation would not alter the assessee's tax liability under the MAT regime. The infrastructure business was already entitled to full deduction on profits, and any higher depreciation rate would only reduce normal income without affecting the book profit taxed under section 115JB. Because the depreciation particulars were already disclosed in the original scrutiny assessment, the attempt to reopen on the same material amounted to a mere change of opinion. The notice and reassessment order were quashed for want of any escapement of income chargeable to tax.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
