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...
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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