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...
Ad hoc disallowance of vehicle depreciation cannot stand without adverse material or a factual basis showing personal use or defective record-keeping; where the assessee asserted log books and audit controls and the Revenue produced no specific rebuttal, the disallowance was treated as arbitrary and deleted. Donations for festivities were held allowable where CBDT circulars covered such payments, and those circulars were binding on the Revenue, so the addition was deleted. For fine and penalty expenditure under section 37(1), the record lacked sufficient factual clarity, and the remand to the Assessing Officer for verification was upheld, leaving that issue open on merits.
Ad hoc disallowance of vehicle depreciation cannot stand without adverse material or a factual basis showing personal use or defective record-keeping; where the assessee asserted log books and audit controls and the Revenue produced no specific rebuttal, the disallowance was treated as arbitrary and deleted. Donations for festivities were held allowable where CBDT circulars covered such payments, and those circulars were binding on the Revenue, so the addition was deleted. For fine and penalty expenditure under section 37(1), the record lacked sufficient factual clarity, and the remand to the Assessing Officer for verification was upheld, leaving that issue open on merits.
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