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...
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Deduction under section 80IA concerned the allowability and apportionment of common salary expenses between a power generation unit and a share trading business. The tribunal accepted the salary claimed as debited to profit and loss but held that the allocation between the two businesses should be made by reference to their respective turnover, not a fixed 50:50 split; it set aside the AO's allocation and directed recomputation of the 80IA deduction by apportioning salary in the ratio of turnover. Grounds raised by the assessee were partly allowed.
Deduction under section 80IA concerned the allowability and apportionment of common salary expenses between a power generation unit and a share trading business. The tribunal accepted the salary claimed as debited to profit and loss but held that the allocation between the two businesses should be made by reference to their respective turnover, not a fixed 50:50 split; it set aside the AO's allocation and directed recomputation of the 80IA deduction by apportioning salary in the ratio of turnover. Grounds raised by the assessee were partly allowed.
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