Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Whether interest on enhanced compensation is taxable or exempt: Holding that plain language of s.56(2)(viii) read with s.145B(1) brings interest on enhanced compensation under "income from other sources," and s.10(37) covers only compensation (not interest); outcome-interest is exigible to tax and exemption claim fails. Whether revision u/s 263 was justified: PCIT found AO failed to make requisite statutory and judicial inquiries (including jurisdictional HC precedents), rendering the assessment erroneous and prejudicial; outcome-revision u/s 263 was valid and recomputation under s.56(2)(viii) r.w.s.145B(1) with s.57(iv) deduction affirmed. - ITAT
Whether interest on enhanced compensation is taxable or exempt: Holding that plain language of s.56(2)(viii) read with s.145B(1) brings interest on enhanced compensation under "income from other sources," and s.10(37) covers only compensation (not interest); outcome-interest is exigible to tax and exemption claim fails. Whether revision u/s 263 was justified: PCIT found AO failed to make requisite statutory and judicial inquiries (including jurisdictional HC precedents), rendering the assessment erroneous and prejudicial; outcome-revision u/s 263 was valid and recomputation under s.56(2)(viii) r.w.s.145B(1) with s.57(iv) deduction affirmed. - ITAT
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