Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Deduction u/s 80IAB on the disallowance of depreciation on Water-use Rights (Intangibles Asset) - The Tribunal acknowledged the payment made by the assessee for water-use rights but concurred with the AO that such rights do not constitute a depreciable capital asset. The Tribunal upheld the AO's decision to disallow depreciation on water-use rights. - However, the Tribunal found merit in the appellant's claim. It observed that the disallowance of depreciation indeed enhanced the profit of the undertaking, making it eligible for deduction under Section 80IAB. The Tribunal cited a CBDT Circular supporting this interpretation. Consequently, it directed the AO to allow the deduction under Section 80IAB on the disallowed depreciation, providing consequential relief to the assessee.
Deduction u/s 80IAB on the disallowance of depreciation on Water-use Rights (Intangibles Asset) - The Tribunal acknowledged the payment made by the assessee for water-use rights but concurred with the AO that such rights do not constitute a depreciable capital asset. The Tribunal upheld the AO's decision to disallow depreciation on water-use rights. - However, the Tribunal found merit in the appellant's claim. It observed that the disallowance of depreciation indeed enhanced the profit of the undertaking, making it eligible for deduction under Section 80IAB. The Tribunal cited a CBDT Circular supporting this interpretation. Consequently, it directed the AO to allow the deduction under Section 80IAB on the disallowed depreciation, providing consequential relief to the assessee.
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