Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
Natural justice was prima facie breached where an unexplained-expenditure addition based on import data was made without meaningful invoice-wise or bill-of-entry-wise particulars. Recorded imports supplied by the assessee exceeded the aggregate data relied on, and apparent duplication in departmental data prevented reconciliation. The High Court treated the addition as raising strong triable issues and stayed recovery pending first appeal, while requiring the appellate authority to decide independently on merits. Administrative directions concerning deposit of a prescribed demand percentage did not fetter the Court's stay power; Revenue's insistence on a 20% payment was rejected. The assessment observations remained confined to the prima facie stay determination.
Natural justice was prima facie breached where an unexplained-expenditure addition based on import data was made without meaningful invoice-wise or bill-of-entry-wise particulars. Recorded imports supplied by the assessee exceeded the aggregate data relied on, and apparent duplication in departmental data prevented reconciliation. The High Court treated the addition as raising strong triable issues and stayed recovery pending first appeal, while requiring the appellate authority to decide independently on merits. Administrative directions concerning deposit of a prescribed demand percentage did not fetter the Court's stay power; Revenue's insistence on a 20% payment was rejected. The assessment observations remained confined to the prima facie stay determination.
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