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...
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The ITAT allowed the deduction u/s 10AA, restoring the assessee's claim. Despite the delay in filing Form 56F, a crucial certification by a Chartered Accountant attesting the correctness of the Section 10AA claim, the form was submitted before the issuance of the intimation u/s 143(1). The Tribunal held that procedural delays should not defeat substantive claims when the required documentation is available before assessment completion, considering the legislative intent to promote exports and economic activity in Special Economic Zones. The disallowance was unjustified as the delayed filing was a procedural lapse not affecting the claim's root. The deduction was restored without remand necessity.
The ITAT allowed the deduction u/s 10AA, restoring the assessee's claim. Despite the delay in filing Form 56F, a crucial certification by a Chartered Accountant attesting the correctness of the Section 10AA claim, the form was submitted before the issuance of the intimation u/s 143(1). The Tribunal held that procedural delays should not defeat substantive claims when the required documentation is available before assessment completion, considering the legislative intent to promote exports and economic activity in Special Economic Zones. The disallowance was unjustified as the delayed filing was a procedural lapse not affecting the claim's root. The deduction was restored without remand necessity.
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