Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Where a taxpayer had diligently pursued rectification within time and filed the statutory challenge within three months of its rejection, the HC held that limitation could not be computed only from the original assessment order. The appellate authority should not have rejected the challenge as time-barred in those circumstances, and if the absence of a specific challenge to the rectification rejection was treated as a defect, amendment ought to have been permitted instead of dismissal on a hyper-technical ground. The limitation-based rejection was set aside and the matter remitted for fresh decision on merits.
Where a taxpayer had diligently pursued rectification within time and filed the statutory challenge within three months of its rejection, the HC held that limitation could not be computed only from the original assessment order. The appellate authority should not have rejected the challenge as time-barred in those circumstances, and if the absence of a specific challenge to the rectification rejection was treated as a defect, amendment ought to have been permitted instead of dismissal on a hyper-technical ground. The limitation-based rejection was set aside and the matter remitted for fresh decision on merits.
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