Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
Validity of reopening of assessment questioned due to errors in original notice. Notice alleged non-filing of return, later contradicted. AO failed to evaluate return before alleging income escape. AO's opinion on income taxation not based on due process. DTAA benefits not part of original notice. Final order relied on assessment from prior year. Allotment of shares under scheme not considered. Reassessment reasons must be consistent. Petitioner refuted remittances, claimed DTAA exemption. AO's denial of treaty benefits without original basis not valid. Court ruled in favor of assessee, criticizing AO's inconsistent approach.
Validity of reopening of assessment questioned due to errors in original notice. Notice alleged non-filing of return, later contradicted. AO failed to evaluate return before alleging income escape. AO's opinion on income taxation not based on due process. DTAA benefits not part of original notice. Final order relied on assessment from prior year. Allotment of shares under scheme not considered. Reassessment reasons must be consistent. Petitioner refuted remittances, claimed DTAA exemption. AO's denial of treaty benefits without original basis not valid. Court ruled in favor of assessee, criticizing AO's inconsistent approach.
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