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...
Legal issues related to income tax assessments, including the designation of tax authorities, allowability of deductions, disallowances under specific sections, transfer pricing adjustments, and procedural aspects. Key points are: Designation of Additional Commissioner as TPO is valid. Pro-rata deduction for leasehold lands allowed, subject to quantum verification. Write-back of provision for doubtful debts remitted for re-examination. Interest on tax refund to be granted as per assessee's claim. Disallowance u/r 8D restricted to exempt income-yielding investments. Such disallowance not applicable for computing book profits u/s 115JB. Expenditure on FCCN issue allowed as debenture issuance cost. Deduction u/s 80G disallowed due to loss. Transfer pricing adjustments on export of vehicles and interest on loans to AEs remitted for re-adjudication. Adjustments on purchase of property from AE and rent from leased property to AE deleted. TDS credit short allowed. Interest u/s 234D upheld. Additional ground regarding time-barred assessment dismissed based on precedent. Concise coverage of critical issues using relevant terminology.
Legal issues related to income tax assessments, including the designation of tax authorities, allowability of deductions, disallowances under specific sections, transfer pricing adjustments, and procedural aspects. Key points are: Designation of Additional Commissioner as TPO is valid. Pro-rata deduction for leasehold lands allowed, subject to quantum verification. Write-back of provision for doubtful debts remitted for re-examination. Interest on tax refund to be granted as per assessee's claim. Disallowance u/r 8D restricted to exempt income-yielding investments. Such disallowance not applicable for computing book profits u/s 115JB. Expenditure on FCCN issue allowed as debenture issuance cost. Deduction u/s 80G disallowed due to loss. Transfer pricing adjustments on export of vehicles and interest on loans to AEs remitted for re-adjudication. Adjustments on purchase of property from AE and rent from leased property to AE deleted. TDS credit short allowed. Interest u/s 234D upheld. Additional ground regarding time-barred assessment dismissed based on precedent. Concise coverage of critical issues using relevant terminology.
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