Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Purchase additions could not be sustained where the taxpayer produced ledgers, invoices, supplier details, registration particulars, bank statements and cheque counterfoils, while undisputed crossed-cheque payments were later realised by third parties. No legal bar then restricted crossed cheques, and the taxpayer could not control their endorsement; absent further inquiry, the High Court restored the first appellate authority's deletion. Wage disallowance based solely on presumed inflation and a doubtful wage register lacked evidentiary support. The High Court set aside the Tribunal's reduced disallowance and restored deletion of both additions; the gross-profit issue remained unanswered.
Purchase additions could not be sustained where the taxpayer produced ledgers, invoices, supplier details, registration particulars, bank statements and cheque counterfoils, while undisputed crossed-cheque payments were later realised by third parties. No legal bar then restricted crossed cheques, and the taxpayer could not control their endorsement; absent further inquiry, the High Court restored the first appellate authority's deletion. Wage disallowance based solely on presumed inflation and a doubtful wage register lacked evidentiary support. The High Court set aside the Tribunal's reduced disallowance and restored deletion of both additions; the gross-profit issue remained unanswered.
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