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...
Related-party payment under section 40A(2)(a) cannot be disallowed unless excessiveness is tested against a truly comparable service; email marketing charges were deleted because the Assessing Officer compared dissimilar services and the record did not support the conclusion of excess payment. Depreciation and car-loan interest were allowed where the vehicles were kept ready for use, since actual use is not the sole test for business assets maintained in a state of readiness. Recruitment, placement and staff welfare es were disallowed because the assessee had admitted during assessment that no employees existed during the year and the amount was offered for disallowance.
Related-party payment under section 40A(2)(a) cannot be disallowed unless excessiveness is tested against a truly comparable service; email marketing charges were deleted because the Assessing Officer compared dissimilar services and the record did not support the conclusion of excess payment. Depreciation and car-loan interest were allowed where the vehicles were kept ready for use, since actual use is not the sole test for business assets maintained in a state of readiness. Recruitment, placement and staff welfare es were disallowed because the assessee had admitted during assessment that no employees existed during the year and the amount was offered for disallowance.
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