Redemption premium on business-funding FCCBs is revenue expenditure and may be spread across the prescribed maturity period.

Pre-commencement project receipts remain capital when tied to installation, while infrastructure deductions follow the taxpayer's chosen initial year.

Tax deducted at source must be considered before prosecuting delayed return filing where the statutory exception applies.

Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...

Notional interest under mercantile accounting cannot be imputed where debtors lack business activity and interest recovery is unsupported.

India-Netherlands treaty taxation: executive search fees and cost reimbursements may fall outside technical services taxation.

Kachha arhtia turnover excludes principals' sale proceeds; tax-audit penalty fails where no books existed for audit.

Foreign income taxed in final settlement proceedings cannot be reassessed under the Black Money Act, preventing double taxation.

Outright software purchases treated as business profits, eliminating withholding where the foreign seller lacks an Indian permanent establishment.

Interest on partners' running accounts and lender accruals remains deductible where tax is deducted and recipients report income.

Business closure expenditure fails the section 37(1) test, while unsupported estimated foreign exchange loss disallowance cannot stand.

Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...

Interest accrual, related investment disallowance, loan genuineness and unquoted-share valuation govern the respective tax adjustments and remand.

Independent corroboration and proven nexus govern additions based on retracted statements, loose sheets, and third-party records.

Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...

Bad-debt deduction for share-broking client dues is available on account write-off without proving actual irrecoverability.

Show cause notice limits and unreliable statements resulted in penalties for alleged courier-based gold smuggling being set aside.

Customs confiscation requires specific notice, hearing and proof of import contravention before penalties or redemption fine may arise.

Prior approval for liquidator-initiated arbitration is mandatory, but post facto approval makes invocation effective from the approval date.

Reasoned fraud-classification orders must address defences; proceedings against an uninvolved former director could not be restarted.