Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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