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...
Denial of concessional tax under the 115BAA regime was addressed on whether late filing of the return u/s 139(4) precludes the option; the analysis holds that absence of an express bar prevents denial solely for filing the return belatedly and that the crucial factor is filing the option form 10IC within the prescribed period. The CBDT circular on condoning delays was deemed inapplicable because there was no delay in filing form 10IC. Procedural delay in form filing should not defeat the assessee's substantive right to concessional tax; assessee appeal allowed.
Denial of concessional tax under the 115BAA regime was addressed on whether late filing of the return u/s 139(4) precludes the option; the analysis holds that absence of an express bar prevents denial solely for filing the return belatedly and that the crucial factor is filing the option form 10IC within the prescribed period. The CBDT circular on condoning delays was deemed inapplicable because there was no delay in filing form 10IC. Procedural delay in form filing should not defeat the assessee's substantive right to concessional tax; assessee appeal allowed.
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