Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
Validity of order passed by PCIT u/s 264 - Non-consideration of submissions of the assessee - Contention of the respondents that it was time barring matter is not acceptable in view of the fact that the relevant assessment order to be revised was received by the petitioner on 4th February, 2020 and as per the statute, limitation is two years from the date of receipt of such assessment order, so, the time for passing the impugned order was becoming barred on 3rd February, 2022 and in view of this fact, the respondent Commissioner could have easily considered the aforesaid objection of the petitioner on 29th March, 2021. There was enough time available to the Commissioner but hastily he passed the impugned order on 29th March, 2021. - HC
Validity of order passed by PCIT u/s 264 - Non-consideration of submissions of the assessee - Contention of the respondents that it was time barring matter is not acceptable in view of the fact that the relevant assessment order to be revised was received by the petitioner on 4th February, 2020 and as per the statute, limitation is two years from the date of receipt of such assessment order, so, the time for passing the impugned order was becoming barred on 3rd February, 2022 and in view of this fact, the respondent Commissioner could have easily considered the aforesaid objection of the petitioner on 29th March, 2021. There was enough time available to the Commissioner but hastily he passed the impugned order on 29th March, 2021. - HC
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