Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Claimed royalty for use of a logo was held deductible under the business expenditure test because the assessee produced the agreement and evidence and the payment was established as wholly and exclusively for business, so the royalty addition was deleted. An addition for undervaluation of closing stock was disallowed applying the consistency principle in stock valuation and tax neutrality of corresponding opening stock adjustments, because the assessee consistently excluded freight as in prior years. A capital subsidy granted as an industrial incentive was not required to be reduced from asset cost under the cited cost-reduction exception, so the related addition was deleted.
Claimed royalty for use of a logo was held deductible under the business expenditure test because the assessee produced the agreement and evidence and the payment was established as wholly and exclusively for business, so the royalty addition was deleted. An addition for undervaluation of closing stock was disallowed applying the consistency principle in stock valuation and tax neutrality of corresponding opening stock adjustments, because the assessee consistently excluded freight as in prior years. A capital subsidy granted as an industrial incentive was not required to be reduced from asset cost under the cited cost-reduction exception, so the related addition was deleted.
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