Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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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