Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
The Tribunal held that the maximum marginal rate was not applicable where the assessee had exercised the section 115BAC option and declared total income of Rs. 1,45,720. On that basis, the impugned intimation applying MMR was set aside and the Assessing Officer was directed to recompute tax without applying MMR. As the surcharge had been levied on the same MMR-based computation, that surcharge also could not stand and was similarly set aside, with recomputation directed on the revised basis.
The Tribunal held that the maximum marginal rate was not applicable where the assessee had exercised the section 115BAC option and declared total income of Rs. 1,45,720. On that basis, the impugned intimation applying MMR was set aside and the Assessing Officer was directed to recompute tax without applying MMR. As the surcharge had been levied on the same MMR-based computation, that surcharge also could not stand and was similarly set aside, with recomputation directed on the revised basis.
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