Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The crux pertains to the inclusion of sale value of old rubber trees in computing book profit u/s 115JB. The Kerala High Court had previously ruled against the assessee in its own case for prior years, holding that the sale value should be included while computing book profit. Although the assessee challenged this before the Supreme Court, the High Court's decision remains binding until set aside. Consequently, the Assessing Officer rightly invoked Section 154 to rectify the mistake of non-inclusion, as non-consideration of judicial precedents constitutes a valid ground for rectification u/s 154. The Tribunal dismissed the assessee's appeal, upholding the Assessing Officer's action, rendering other grounds raised by the assessee redundant.
The crux pertains to the inclusion of sale value of old rubber trees in computing book profit u/s 115JB. The Kerala High Court had previously ruled against the assessee in its own case for prior years, holding that the sale value should be included while computing book profit. Although the assessee challenged this before the Supreme Court, the High Court's decision remains binding until set aside. Consequently, the Assessing Officer rightly invoked Section 154 to rectify the mistake of non-inclusion, as non-consideration of judicial precedents constitutes a valid ground for rectification u/s 154. The Tribunal dismissed the assessee's appeal, upholding the Assessing Officer's action, rendering other grounds raised by the assessee redundant.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
