Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
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Return-processing adjustments cannot disallow diminution in the value of a business-purpose investment in a wholly owned subsidiary solely because a tax audit report describes it as capital expenditure where binding jurisdictional precedent permits an analogous business loss. Once an intimation is issued after considering the taxpayer's response, the Centralised Processing Centre performs a quasi-judicial function and must follow binding High Court law. Failure to consider a jurisdictional High Court decision delivered before the intimation, and specifically raised in a rectification application, constitutes a mistake apparent from the record. The resulting disallowance requires rectification in accordance with that precedent.
Return-processing adjustments cannot disallow diminution in the value of a business-purpose investment in a wholly owned subsidiary solely because a tax audit report describes it as capital expenditure where binding jurisdictional precedent permits an analogous business loss. Once an intimation is issued after considering the taxpayer's response, the Centralised Processing Centre performs a quasi-judicial function and must follow binding High Court law. Failure to consider a jurisdictional High Court decision delivered before the intimation, and specifically raised in a rectification application, constitutes a mistake apparent from the record. The resulting disallowance requires rectification in accordance with that precedent.
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