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...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Consistency in the assessee's own case governed the treatment of alleged notional interest on advances to a subsidiary: the addition was deleted because the issue had already been decided in the assessee's favour on identical facts, and the Revenue showed no distinguishing fact or change in law for the year. Pendency of earlier Revenue appeals before the High Court did not, by itself, justify departure from the settled view. The note records that the notional interest addition was therefore upheld as deleted for the relevant year.
Consistency in the assessee's own case governed the treatment of alleged notional interest on advances to a subsidiary: the addition was deleted because the issue had already been decided in the assessee's favour on identical facts, and the Revenue showed no distinguishing fact or change in law for the year. Pendency of earlier Revenue appeals before the High Court did not, by itself, justify departure from the settled view. The note records that the notional interest addition was therefore upheld as deleted for the relevant year.
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