Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
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...
Export turnover and total turnover must be computed on a parity basis for Section 10A deduction, so foreign-exchange expenditure excluded from export turnover must also be excluded from total turnover; the issue was decided for the assessee. Depreciation claims relating to goodwill and non-compete rights were not finally determined, as the matter was remitted for reconsideration in light of the Supreme Court's guidance on acquisition parameters. Apportionment of common disallowance between STP and non-STP units was treated as a factual question, and the concurrent view that a lump-sum disallowance was improper was upheld for the assessee. Interest disallowance on advances to subsidiaries was remitted for fresh examination on whether the investment had a business nexus.
Export turnover and total turnover must be computed on a parity basis for Section 10A deduction, so foreign-exchange expenditure excluded from export turnover must also be excluded from total turnover; the issue was decided for the assessee. Depreciation claims relating to goodwill and non-compete rights were not finally determined, as the matter was remitted for reconsideration in light of the Supreme Court's guidance on acquisition parameters. Apportionment of common disallowance between STP and non-STP units was treated as a factual question, and the concurrent view that a lump-sum disallowance was improper was upheld for the assessee. Interest disallowance on advances to subsidiaries was remitted for fresh examination on whether the investment had a business nexus.
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