Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Audit report-based adjustment was permissible in prima facie processing where Clause 21(h) of Form 3CD disclosed a quantified section 14A disallowance not fully reflected in the return, because the amended processing provision allows such a limited adjustment; the jurisdictional challenge therefore failed for A.Y. 2022-23. Rectification that later enhanced liability on the same issue was invalid for A.Y. 2021-22, because section 154 requires notice, a reasonable opportunity of hearing, and proper consideration of the assessee's reply before increasing liability. On merits, the section 14A disallowance for both years was restricted to the amount already offered, since part of the reported figure had already been disallowed in computation and a larger disallowance could not be made without the required recorded dissatisfaction.
Audit report-based adjustment was permissible in prima facie processing where Clause 21(h) of Form 3CD disclosed a quantified section 14A disallowance not fully reflected in the return, because the amended processing provision allows such a limited adjustment; the jurisdictional challenge therefore failed for A.Y. 2022-23. Rectification that later enhanced liability on the same issue was invalid for A.Y. 2021-22, because section 154 requires notice, a reasonable opportunity of hearing, and proper consideration of the assessee's reply before increasing liability. On merits, the section 14A disallowance for both years was restricted to the amount already offered, since part of the reported figure had already been disallowed in computation and a larger disallowance could not be made without the required recorded dissatisfaction.
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