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...
Collateral challenge to the jurisdiction of reassessment proceedings was held maintainable in an appeal against penalty where the penalty was founded on that reassessment. After three years from the end of the relevant assessment year, approval for notice under section 148 had to be obtained from the authority specified in section 151(ii); approval by the PCIT was insufficient. Because the notice under section 148 and the reassessment order were issued with the wrong sanction, the reassessment was void and the consequential penalty under section 271E could not survive.
Collateral challenge to the jurisdiction of reassessment proceedings was held maintainable in an appeal against penalty where the penalty was founded on that reassessment. After three years from the end of the relevant assessment year, approval for notice under section 148 had to be obtained from the authority specified in section 151(ii); approval by the PCIT was insufficient. Because the notice under section 148 and the reassessment order were issued with the wrong sanction, the reassessment was void and the consequential penalty under section 271E could not survive.
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