Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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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