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...
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Contribution paid to an insurer under a leave encashment scheme is treated as actual business expenditure, distinct from a mere provision, and CSR spending mandated under port guidelines is viewed as business-linked, with the statutory disallowance operating prospectively. Disputed enhanced estate rentals are not taxable as real income where recoverability remains uncertain, and port infrastructure such as docks, sea walls, piers and railway assets may qualify as plant under the functional test for depreciation. Consequential disallowance for short deduction of tax at source falls once the underlying TDS default is deleted, and employee welfare and labour-related contributions are allowable where made for commercial expediency.
Contribution paid to an insurer under a leave encashment scheme is treated as actual business expenditure, distinct from a mere provision, and CSR spending mandated under port guidelines is viewed as business-linked, with the statutory disallowance operating prospectively. Disputed enhanced estate rentals are not taxable as real income where recoverability remains uncertain, and port infrastructure such as docks, sea walls, piers and railway assets may qualify as plant under the functional test for depreciation. Consequential disallowance for short deduction of tax at source falls once the underlying TDS default is deleted, and employee welfare and labour-related contributions are allowable where made for commercial expediency.
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