Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Club membership and subscription expenditure is deductible where its business purpose and nexus are established; an ad hoc disallowance requires identification of particular personal or non-business payments, resulting in deletion of the club-expense disallowance. Where own funds exceed exempt-income investments and borrowings serve specified business purposes, investments are presumed funded from own funds, eliminating interest disallowance under section 14A. Administrative disallowance must have a rational nexus to, and cannot exceed, exempt income. Internal handover, capitalisation and deployment records can establish that machinery was put to use, supporting depreciation and additional depreciation. Electrical installations integral to manufacturing machinery qualify as plant and machinery for additional depreciation. Both appeals were partly allowed.
Club membership and subscription expenditure is deductible where its business purpose and nexus are established; an ad hoc disallowance requires identification of particular personal or non-business payments, resulting in deletion of the club-expense disallowance. Where own funds exceed exempt-income investments and borrowings serve specified business purposes, investments are presumed funded from own funds, eliminating interest disallowance under section 14A. Administrative disallowance must have a rational nexus to, and cannot exceed, exempt income. Internal handover, capitalisation and deployment records can establish that machinery was put to use, supporting depreciation and additional depreciation. Electrical installations integral to manufacturing machinery qualify as plant and machinery for additional depreciation. Both appeals were partly allowed.
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