Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Issue: Whether blocking electronic input tax credit under Rule 86A was predicated on an independent, reasoned satisfaction or on a mechanical/borrowed conclusion. Reasoning: The court held that Rule 86A requires an independent application of mind and a speaking order; reliance on the Board's Circular dated 02.11.2021 does not permit a mere mechanical exercise or borrowed satisfaction. Outcome: The tax authority was directed to pass a fresh reasoned speaking order complying with Rule 86A, and the writ was disposed. - HC
Issue: Whether blocking electronic input tax credit under Rule 86A was predicated on an independent, reasoned satisfaction or on a mechanical/borrowed conclusion. Reasoning: The court held that Rule 86A requires an independent application of mind and a speaking order; reliance on the Board's Circular dated 02.11.2021 does not permit a mere mechanical exercise or borrowed satisfaction. Outcome: The tax authority was directed to pass a fresh reasoned speaking order complying with Rule 86A, and the writ was disposed. - HC
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