Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Adoption of CERC tariff for internal bagasse transfer was rejected because treating bagasse as a by product with captive consumption, cost analysis using FRP and third party quotations produced a more realistic arm's length price; the Tribunal directed acceptance of the assessee's Rs.1,500/ton transfer price. The write off of loans/advances to a wholly owned subsidiary was held to be a business loss incurred for commercial expediency and allowable under the law as a deduction under business loss provisions. Harvesting and transport payments were found not to attract withholding under contract withholding rules, so no disallowance under withholding non compliance was warranted. Dispute on interest deduction timing requires AO verification under payment timing rules.
Adoption of CERC tariff for internal bagasse transfer was rejected because treating bagasse as a by product with captive consumption, cost analysis using FRP and third party quotations produced a more realistic arm's length price; the Tribunal directed acceptance of the assessee's Rs.1,500/ton transfer price. The write off of loans/advances to a wholly owned subsidiary was held to be a business loss incurred for commercial expediency and allowable under the law as a deduction under business loss provisions. Harvesting and transport payments were found not to attract withholding under contract withholding rules, so no disallowance under withholding non compliance was warranted. Dispute on interest deduction timing requires AO verification under payment timing rules.
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