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...
Ten-year block computation was governed by the operative date of the satisfaction note (29-09-2021), which placed AYs 2011-12 and 2012-13 outside the ten-year block and resulted in quashing of those assessments. Separately, the assumption of jurisdiction under the search-related provision was held invalid because the seized material did not contain incriminating information attributable to the assessee; verbatim satisfaction notes, a non contemporaneous excel sheet created by searched person staff and lack of corroboration defeated evidentiary value. Consequent additions were deleted and the revenue appeals dismissed.
Ten-year block computation was governed by the operative date of the satisfaction note (29-09-2021), which placed AYs 2011-12 and 2012-13 outside the ten-year block and resulted in quashing of those assessments. Separately, the assumption of jurisdiction under the search-related provision was held invalid because the seized material did not contain incriminating information attributable to the assessee; verbatim satisfaction notes, a non contemporaneous excel sheet created by searched person staff and lack of corroboration defeated evidentiary value. Consequent additions were deleted and the revenue appeals dismissed.
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