Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Depreciation on franchise rights was allowed on the full actual cost of the intangible asset, because the franchise licence was acquired when the agreement was executed and annual instalments did not limit the asset's cost; any later adjustment would affect subsequent years. Cash payments for daily allowances were disallowed under section 40A(3) because the relevant test is the actual payment to a person in a day, and no Rule 6DD exception was proved. Business research and routed remuneration claims failed for want of proof of actual services and business nexus, while the ad hoc percentage disallowance of web support expenses was deleted for lack of evidentiary basis. Security expenses were allowed on commercial expediency, and several reimbursement, TDS credit and brought-forward loss issues were remanded for verification.
Depreciation on franchise rights was allowed on the full actual cost of the intangible asset, because the franchise licence was acquired when the agreement was executed and annual instalments did not limit the asset's cost; any later adjustment would affect subsequent years. Cash payments for daily allowances were disallowed under section 40A(3) because the relevant test is the actual payment to a person in a day, and no Rule 6DD exception was proved. Business research and routed remuneration claims failed for want of proof of actual services and business nexus, while the ad hoc percentage disallowance of web support expenses was deleted for lack of evidentiary basis. Security expenses were allowed on commercial expediency, and several reimbursement, TDS credit and brought-forward loss issues were remanded for verification.
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