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...
ITAT held that the plea of denial of opportunity in assessment was factually untenable because statutory notices were issued, replies were filed, and the assessee had not raised the grievance before the first appellate authority. It further held that the dispute concerned only the year of taxability of contractual receipts, which depended on the accounting method actually followed. As the assessee failed to substantiate the claimed completed service contract method, had received the amounts in the relevant year, and the receipts were reflected in Form 26AS with tax deduction, the additions were sustained and the receipts were taxable in Assessment Year 2018-19.
ITAT held that the plea of denial of opportunity in assessment was factually untenable because statutory notices were issued, replies were filed, and the assessee had not raised the grievance before the first appellate authority. It further held that the dispute concerned only the year of taxability of contractual receipts, which depended on the accounting method actually followed. As the assessee failed to substantiate the claimed completed service contract method, had received the amounts in the relevant year, and the receipts were reflected in Form 26AS with tax deduction, the additions were sustained and the receipts were taxable in Assessment Year 2018-19.
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