Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Income from sale of assets of a bank under liquidation was held not to be diverted at source by overriding title in favour of DICGC; the income accrued to the official liquidator, and the claim of no taxable accrual was rejected. In rectification proceedings, the Tribunal held that the set-off of deemed short-term capital gain on depreciable assets against brought forward business loss was a debatable issue and could not be corrected as an apparent mistake under section 154; the rectification order was quashed. It also held that a bad debt written off in the ordinary course of banking business satisfied the statutory conditions, and actual proof of irrecoverability was not required once the write-off was made; the disallowance was deleted.
Income from sale of assets of a bank under liquidation was held not to be diverted at source by overriding title in favour of DICGC; the income accrued to the official liquidator, and the claim of no taxable accrual was rejected. In rectification proceedings, the Tribunal held that the set-off of deemed short-term capital gain on depreciable assets against brought forward business loss was a debatable issue and could not be corrected as an apparent mistake under section 154; the rectification order was quashed. It also held that a bad debt written off in the ordinary course of banking business satisfied the statutory conditions, and actual proof of irrecoverability was not required once the write-off was made; the disallowance was deleted.
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