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...
The ITAT addressed multiple revenue and business expense issues, holding that advances from customers already accounted for under sale agreements or the Percentage of Completion Method could not be added again, and that notional interest on business advances or imprest could not be taxed as hypothetical income. It sustained deletion of disallowances where invoices, payment evidence, or business nexus were verified, but upheld a disallowance for advertisement expense found unrelated to business. It also held that section 14A disallowance could not survive in the absence of exempt income, and accepted prior period expenses where liability had crystallized. Certain issues on revised computation, advertisement, consultancy and withholding tax were remanded for verification, while employee accommodation commission and brokerage and write-off of advances were allowed as deductible business loss.
The ITAT addressed multiple revenue and business expense issues, holding that advances from customers already accounted for under sale agreements or the Percentage of Completion Method could not be added again, and that notional interest on business advances or imprest could not be taxed as hypothetical income. It sustained deletion of disallowances where invoices, payment evidence, or business nexus were verified, but upheld a disallowance for advertisement expense found unrelated to business. It also held that section 14A disallowance could not survive in the absence of exempt income, and accepted prior period expenses where liability had crystallized. Certain issues on revised computation, advertisement, consultancy and withholding tax were remanded for verification, while employee accommodation commission and brokerage and write-off of advances were allowed as deductible business loss.
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