Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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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