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...
Characterisation of software expenditure focused on whether payments were capital or revenue; the payments were held to be recurring annual maintenance, database support and licence renewal costs conferring only annual benefits, with no transfer of ownership, no creation of a software asset or enduring benefit to the assessee's asset base. The assessing officer failed to produce cogent material showing a capital asset arose. Operative effect: the payments were treated as revenue expenditure and allowable under income-tax deductibility principles, leading to deletion of the addition and dismissal of the revenue appeal.
Characterisation of software expenditure focused on whether payments were capital or revenue; the payments were held to be recurring annual maintenance, database support and licence renewal costs conferring only annual benefits, with no transfer of ownership, no creation of a software asset or enduring benefit to the assessee's asset base. The assessing officer failed to produce cogent material showing a capital asset arose. Operative effect: the payments were treated as revenue expenditure and allowable under income-tax deductibility principles, leading to deletion of the addition and dismissal of the revenue appeal.
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