Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Business expenses - CSR - The expenditure could be related to ‘Commercial Expediency’, as any amount contributed to the BATF would generate goodwill of the local community as well as the Government Authorities. It must also be emphasised that the concept of ‘Commercial Expediency’ is from the perspective of an assessee and cannot be judged from the perspective of what the Revenue construes it to be ‘Commercial expediency.’ - As the subject matter of dispute relates to assessment year 2010-11, it can be stated that the said explanation to Section 37 of the I.T. Act would not apply as regards the present subject matter of dispute. - HC
Business expenses - CSR - The expenditure could be related to ‘Commercial Expediency’, as any amount contributed to the BATF would generate goodwill of the local community as well as the Government Authorities. It must also be emphasised that the concept of ‘Commercial Expediency’ is from the perspective of an assessee and cannot be judged from the perspective of what the Revenue construes it to be ‘Commercial expediency.’ - As the subject matter of dispute relates to assessment year 2010-11, it can be stated that the said explanation to Section 37 of the I.T. Act would not apply as regards the present subject matter of dispute. - HC
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