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...
Section 153C jurisdiction is treated as constructively satisfied where the same Assessing Officer handles the searched person and the other person, so physical handover of seized material is not essential once the officer applies his mind. One consolidated satisfaction note can cover the six-year block under sections 153C and 153A, and an Investigation Wing trigger is not fatal by itself. On limitation, the assessments were time-barred because the relevant date, whether taken as the search, constructive handover, conclusion of Settlement Commission proceedings, or recording of satisfaction, placed the proceedings outside the statutory period. Additions based on uncorroborated third-party excel sheets were unsustainable where identity was doubtful and cross-examination was denied.
Section 153C jurisdiction is treated as constructively satisfied where the same Assessing Officer handles the searched person and the other person, so physical handover of seized material is not essential once the officer applies his mind. One consolidated satisfaction note can cover the six-year block under sections 153C and 153A, and an Investigation Wing trigger is not fatal by itself. On limitation, the assessments were time-barred because the relevant date, whether taken as the search, constructive handover, conclusion of Settlement Commission proceedings, or recording of satisfaction, placed the proceedings outside the statutory period. Additions based on uncorroborated third-party excel sheets were unsustainable where identity was doubtful and cross-examination was denied.
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