Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displa...
Book-entry conversion of compulsorily convertible debentures into compulsorily convertible preference shares did not constitute a sum received during the relevant previous year for the cash-credit provision. Share premium arising solely from that conversion therefore could not be treated as an unexplained cash credit, rendering the related addition unsustainable. Penalty founded solely on the deleted share-premium addition had no surviving basis. Penalty for non-reporting income also did not arise for principal additions that were set aside; for additions remanded for fresh consideration, penalty could be considered only if they were reiterated. The Revenue's appeals were dismissed for want of a substantial question of law.
Book-entry conversion of compulsorily convertible debentures into compulsorily convertible preference shares did not constitute a sum received during the relevant previous year for the cash-credit provision. Share premium arising solely from that conversion therefore could not be treated as an unexplained cash credit, rendering the related addition unsustainable. Penalty founded solely on the deleted share-premium addition had no surviving basis. Penalty for non-reporting income also did not arise for principal additions that were set aside; for additions remanded for fresh consideration, penalty could be considered only if they were reiterated. The Revenue's appeals were dismissed for want of a substantial question of law.
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