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...
Limitation on carry forward of capital losses was applied: the Tribunal found the assessee did not rebut the revenue's contention or show entitlement to set off a carry forward capital loss beyond the eight succeeding assessment years in which the loss was first computed, and upheld the disallowance of that setoff. On deductibility, the Tribunal treated interest received on enhanced/delayed compensation as income from other sources and held it deductible under the statutory provision governing interest deductions, setting aside the appellate finding and directing the Assessing Officer to allow the deduction accordingly.
Limitation on carry forward of capital losses was applied: the Tribunal found the assessee did not rebut the revenue's contention or show entitlement to set off a carry forward capital loss beyond the eight succeeding assessment years in which the loss was first computed, and upheld the disallowance of that setoff. On deductibility, the Tribunal treated interest received on enhanced/delayed compensation as income from other sources and held it deductible under the statutory provision governing interest deductions, setting aside the appellate finding and directing the Assessing Officer to allow the deduction accordingly.
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