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...
Reassessment initiated under an incorrect and non-operative PAN was treated as a jurisdictional defect, not a mere procedural lapse, because the assessee had disclosed the transactions under the correct PAN and the reply under section 148A was not considered before issuing notice; the proceedings were also held time-barred. On merits, cash deposits were accepted as business receipts where the books and explanation were unrebutted, and rejection of accounts solely for want of a tax audit was unjustified. The FDR investments were likewise explained from renewal of earlier deposits and the same business receipts, so the addition could not survive and double taxation of the same funds was impermissible.
Reassessment initiated under an incorrect and non-operative PAN was treated as a jurisdictional defect, not a mere procedural lapse, because the assessee had disclosed the transactions under the correct PAN and the reply under section 148A was not considered before issuing notice; the proceedings were also held time-barred. On merits, cash deposits were accepted as business receipts where the books and explanation were unrebutted, and rejection of accounts solely for want of a tax audit was unjustified. The FDR investments were likewise explained from renewal of earlier deposits and the same business receipts, so the addition could not survive and double taxation of the same funds was impermissible.
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