Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
Internal comparable pricing for captive power transfers was accepted where the same consuming units bought electricity from State distribution companies in the same market and period, resulting in deletion of transfer-pricing adjustments. Exempt-income disallowance was confined to dividend-yielding investments, and MAT adjustments required an independent determination of expenditure from the accounts. Expansion-related operating costs remained revenue expenditure unless directly attributable to acquiring or installing capital assets. Captive rail systems qualified as infrastructure facilities for section 80-IA, while common costs required expenditure-based allocation supported by a nexus. Incentives linked to capital investment and expansion were treated as capital receipts and excluded from book profit. The notes also address investment allowance, additional depreciation, bad debts, leave encashment, and specified MAT adjustments.
Internal comparable pricing for captive power transfers was accepted where the same consuming units bought electricity from State distribution companies in the same market and period, resulting in deletion of transfer-pricing adjustments. Exempt-income disallowance was confined to dividend-yielding investments, and MAT adjustments required an independent determination of expenditure from the accounts. Expansion-related operating costs remained revenue expenditure unless directly attributable to acquiring or installing capital assets. Captive rail systems qualified as infrastructure facilities for section 80-IA, while common costs required expenditure-based allocation supported by a nexus. Incentives linked to capital investment and expansion were treated as capital receipts and excluded from book profit. The notes also address investment allowance, additional depreciation, bad debts, leave encashment, and specified MAT adjustments.
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