Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Disallowance of salary expenses was reversed where the taxpayer produced employee-wise breakup, designations, locations and salary details and no evidence of sham payments or diversion of funds was shown; AO's salary disallowance deleted. Non-deduction of tax at source on cross-border/reimbursement payments was held not to be a standalone ground for disallowance where payments were characterised as reimbursements, supported by particulars and did not prima facie attract TDS; 40(a)(i) addition deleted. Addition for alleged undisclosed receipts was deleted after the assessee furnished corresponding receipt particulars and TDS credit documentation, and Revenue produced no contrary proof. Appeal dismissed.
Disallowance of salary expenses was reversed where the taxpayer produced employee-wise breakup, designations, locations and salary details and no evidence of sham payments or diversion of funds was shown; AO's salary disallowance deleted. Non-deduction of tax at source on cross-border/reimbursement payments was held not to be a standalone ground for disallowance where payments were characterised as reimbursements, supported by particulars and did not prima facie attract TDS; 40(a)(i) addition deleted. Addition for alleged undisclosed receipts was deleted after the assessee furnished corresponding receipt particulars and TDS credit documentation, and Revenue produced no contrary proof. Appeal dismissed.
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