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...
The article explains that the Finance Act 2020 amendment (effective 01.04.2020) expanded the definition of "eligible assessee" in Section 144C(15)(b) to include non-resident individuals, so the petitioner (an NRI) qualified as an eligible assessee at the time of the Section 148 notice; proceedings before the Dispute Resolution Panel under Section 144C extended limitation via Section 153, and the petitioner's post hoc Section 154 rectification was treated as an afterthought. The court found estoppel by the petitioner's conduct (including filing objections) and refused the challenge to jurisdiction absent a Transfer Order under Section 127, dismissing the writ petition.
The article explains that the Finance Act 2020 amendment (effective 01.04.2020) expanded the definition of "eligible assessee" in Section 144C(15)(b) to include non-resident individuals, so the petitioner (an NRI) qualified as an eligible assessee at the time of the Section 148 notice; proceedings before the Dispute Resolution Panel under Section 144C extended limitation via Section 153, and the petitioner's post hoc Section 154 rectification was treated as an afterthought. The court found estoppel by the petitioner's conduct (including filing objections) and refused the challenge to jurisdiction absent a Transfer Order under Section 127, dismissing the writ petition.
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