Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
The central issue was whether the approval authorizing a special audit under s.142(2A) complied with Circular No.19/2019 by bearing a DIN and requisite manual-issuance justification; the court held the approval dated 06.02.2025 lacked a DIN and any exceptional-circumstances endorsement, violating the Circular and settled precedent that jurisdictional communications (including approvals/sanctions) must carry a DIN. Legal basis: Circular No.19/2019 and prior HC rulings invalidating DIN-less sanctions. Outcome: the approval is non est in law and the subsequent order directing a special audit is without jurisdiction - decided for the assessee. - HC
The central issue was whether the approval authorizing a special audit under s.142(2A) complied with Circular No.19/2019 by bearing a DIN and requisite manual-issuance justification; the court held the approval dated 06.02.2025 lacked a DIN and any exceptional-circumstances endorsement, violating the Circular and settled precedent that jurisdictional communications (including approvals/sanctions) must carry a DIN. Legal basis: Circular No.19/2019 and prior HC rulings invalidating DIN-less sanctions. Outcome: the approval is non est in law and the subsequent order directing a special audit is without jurisdiction - decided for the assessee. - HC
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