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...
Penalty u/s 271(1)(c) was imposed for disallowance of depreciation on non-compete fees. The CIT(A) relied on Sharp Business System [2012 (11) TMI 324 - Delhi High Court], which is under challenge before the Supreme Court. Pepsico India Holding Pvt. Ltd. [2024 (4) TMI 1154 - Delhi High Court] allowed depreciation on non-compete fees after considering Sharp Business System. Different High Courts have divergent views on allowability of depreciation on non-compete fees, and the matter is pending before the Supreme Court. Considering the contentious issue, provisions of Section 271(1)(c) cannot be attracted. Assessee's appeal allowed.
Penalty u/s 271(1)(c) was imposed for disallowance of depreciation on non-compete fees. The CIT(A) relied on Sharp Business System [2012 (11) TMI 324 - Delhi High Court], which is under challenge before the Supreme Court. Pepsico India Holding Pvt. Ltd. [2024 (4) TMI 1154 - Delhi High Court] allowed depreciation on non-compete fees after considering Sharp Business System. Different High Courts have divergent views on allowability of depreciation on non-compete fees, and the matter is pending before the Supreme Court. Considering the contentious issue, provisions of Section 271(1)(c) cannot be attracted. Assessee's appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
