Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
Software expenditure was held to require a year-specific functional test: software forming part of the profit-making apparatus and enhancing system capacity or functionality was treated as capital expenditure with depreciation allowable, while routine subscription-based software was allowed as revenue expenditure. Section 14A disallowance was confined by applying the presumption that investments were made out of own funds where interest-free funds exceeded investments, and Rule 8D(2)(iii) was restricted to investments that actually yielded exempt income; no MAT addition followed where there was no disallowance under Rule 8D(2)(i). Debenture Redemption Reserve was held to be a provision for a known liability set apart for debenture redemption, not an unascertained reserve, and was excluded from book profit under section 115JB.
Software expenditure was held to require a year-specific functional test: software forming part of the profit-making apparatus and enhancing system capacity or functionality was treated as capital expenditure with depreciation allowable, while routine subscription-based software was allowed as revenue expenditure. Section 14A disallowance was confined by applying the presumption that investments were made out of own funds where interest-free funds exceeded investments, and Rule 8D(2)(iii) was restricted to investments that actually yielded exempt income; no MAT addition followed where there was no disallowance under Rule 8D(2)(i). Debenture Redemption Reserve was held to be a provision for a known liability set apart for debenture redemption, not an unascertained reserve, and was excluded from book profit under section 115JB.
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