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...
Revision under revisional jurisdiction challenged the deductibility of provisions for 'standard assets' claimed as bad and doubtful debts under the income tax deduction provision for banks. The Tribunal analysed the RBI Master Direction definition of standard assets and construed the deduction provision, noting conflicting coordinate bench decisions but following consistent precedents that allow provisions for standard assets. Applying those precedents, the Tribunal quashed the revisional proceedings insofar as they sought to disallow the provision and restored the assessment outcome favourable to the assessee for the relevant year.
Revision under revisional jurisdiction challenged the deductibility of provisions for 'standard assets' claimed as bad and doubtful debts under the income tax deduction provision for banks. The Tribunal analysed the RBI Master Direction definition of standard assets and construed the deduction provision, noting conflicting coordinate bench decisions but following consistent precedents that allow provisions for standard assets. Applying those precedents, the Tribunal quashed the revisional proceedings insofar as they sought to disallow the provision and restored the assessment outcome favourable to the assessee for the relevant year.
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