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...
Interest on borrowings used to acquire plant, machinery, scrap, land and buildings held as current assets for sale in an asset-trading business is revenue expenditure. The proviso to section 36(1)(iii), which restricts interest deduction until an acquired asset is first put to use, does not apply where the assets are acquired solely for resale and are neither intended nor required to be used in manufacturing. Borrowings for buying and selling such assets are for business purposes. Acquisition-related expenses incurred in dealing in current assets for sale are likewise revenue expenditure allowable under section 37(1), rather than capital expenditure.
Interest on borrowings used to acquire plant, machinery, scrap, land and buildings held as current assets for sale in an asset-trading business is revenue expenditure. The proviso to section 36(1)(iii), which restricts interest deduction until an acquired asset is first put to use, does not apply where the assets are acquired solely for resale and are neither intended nor required to be used in manufacturing. Borrowings for buying and selling such assets are for business purposes. Acquisition-related expenses incurred in dealing in current assets for sale are likewise revenue expenditure allowable under section 37(1), rather than capital expenditure.
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