NPCI-based bank account validation for IEC applications and modifications enables real-time validation; incorrect details block submission or trigger ...
Creation/Invocation of pledge of securities through depository system: standardized pledge forms, notice requirement and invocation notifications to p...
Calendar Spread margin benefit for Single Stock Derivatives suspended on expiry day for expiring contracts; exchanges must implement systems and rule ...
Proportionate interest, unexplained credits and partner remuneration disputed; proofs of fund nexus and lender identity were decisive and disallowance...
Capital gains valuation from stamp assessment versus net consideration for residential reinvestment: deemed stamp value replaced for gains but not for...
Reassessment for disallowing higher depreciation on computer software was held time-barred because the original scrutiny assessment was based on a full and true disclosure, and the Revenue relied only on the same return, financials, and depreciation statement without any subsequent tangible material; hence the proviso to s.147 could not extend limitation and reopening amounted to impermissible review. Consequently, limitation was reckoned from the original assessment date, as the later s.143(3) r/w s.263 order dealt only with s.10A/10B computation and did not merge on the depreciation issue, rendering the reopening without jurisdiction. On merits, computer software was eligible for 60% depreciation under the then-existing "computers" entry, as no separate software entry existed pre-AY 2003-04, so the higher rate was allowable. - HC
Reassessment for disallowing higher depreciation on computer software was held time-barred because the original scrutiny assessment was based on a full and true disclosure, and the Revenue relied only on the same return, financials, and depreciation statement without any subsequent tangible material; hence the proviso to s.147 could not extend limitation and reopening amounted to impermissible review. Consequently, limitation was reckoned from the original assessment date, as the later s.143(3) r/w s.263 order dealt only with s.10A/10B computation and did not merge on the depreciation issue, rendering the reopening without jurisdiction. On merits, computer software was eligible for 60% depreciation under the then-existing "computers" entry, as no separate software entry existed pre-AY 2003-04, so the higher rate was allowable. - HC
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