Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Strict res judicata does not apply in income-tax proceedings, but the Revenue cannot depart from an earlier accepted position on identical facts without a material change in fact or law, and appellate authorities may entertain claims raised through notes to the return where the material is already on record; CBDT instructions cannot override the Act. Actuarially determined pension and employee-benefit provisions were treated as ascertained liabilities deductible under section 37(1), while leave encashment remained allowable only on actual payment. The Tribunal also applied real income principles in deleting additions on NPA interest and allowed valuation of bank securities at lower of cost or market value on a scrip-wise basis. Several other claims were remanded for verification, and some disallowances were upheld or rejected on settled precedent.
Strict res judicata does not apply in income-tax proceedings, but the Revenue cannot depart from an earlier accepted position on identical facts without a material change in fact or law, and appellate authorities may entertain claims raised through notes to the return where the material is already on record; CBDT instructions cannot override the Act. Actuarially determined pension and employee-benefit provisions were treated as ascertained liabilities deductible under section 37(1), while leave encashment remained allowable only on actual payment. The Tribunal also applied real income principles in deleting additions on NPA interest and allowed valuation of bank securities at lower of cost or market value on a scrip-wise basis. Several other claims were remanded for verification, and some disallowances were upheld or rejected on settled precedent.
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