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...
Revision under section 263 failed because CSR expenditure cannot be added to book profit under section 115JB except through the specific adjustments in the Explanation, and the Assessing Officer had no power to alter the audited accounts beyond those statutory items. The Tribunal also held that a section 14A read with Rule 8D disallowance cannot be imported into MAT book profit when tax liability is determined under section 115JB, so the omission to examine that issue caused no prejudice to the Revenue. As neither ground made the assessment order both erroneous and prejudicial, the revisionary order was quashed.
Revision under section 263 failed because CSR expenditure cannot be added to book profit under section 115JB except through the specific adjustments in the Explanation, and the Assessing Officer had no power to alter the audited accounts beyond those statutory items. The Tribunal also held that a section 14A read with Rule 8D disallowance cannot be imported into MAT book profit when tax liability is determined under section 115JB, so the omission to examine that issue caused no prejudice to the Revenue. As neither ground made the assessment order both erroneous and prejudicial, the revisionary order was quashed.
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