Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Whether disallowance under section 14A read with Rule 8D required prior recording of satisfaction: held that s.14A(2) mandates that the assessing officer must record satisfaction or dissatisfaction regarding the correctness of expenditure claimed before making an addition; absence of such recorded dissatisfaction renders the disallowance impermissible. Applying this legal precondition, the Tribunal and the appellate tax authority's factual findings rejecting the Revenue's adjustment were upheld and the Revenue's appeal dismissed. - HC
Whether disallowance under section 14A read with Rule 8D required prior recording of satisfaction: held that s.14A(2) mandates that the assessing officer must record satisfaction or dissatisfaction regarding the correctness of expenditure claimed before making an addition; absence of such recorded dissatisfaction renders the disallowance impermissible. Applying this legal precondition, the Tribunal and the appellate tax authority's factual findings rejecting the Revenue's adjustment were upheld and the Revenue's appeal dismissed. - HC
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