Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Interest on unutilised government grant deposits was not taxable where the grant terms and accounts showed the funds and accrued interest belonged to the Government and the assessee remained only a custodian; the addition was deleted. TDS credit was not denied merely because the related interest was not taxable in the assessee's hands, as Rule 37BA credits tax to the deductee shown by the deductor, subject only to verification against any double claim; the matter was restored for that limited purpose. For MAT, interest on unutilised grant deposits and belated provident fund payment could not be added back unless covered by Explanation 1 to section 115JB, so those adjustments were deleted, while the provision for obsolete material was remitted for factual verification as to whether it was a provision or ascertained liability. Interest under section 234A could not be levied by reference to a revised return, because the provision applies only to delay in the original return; the levy was deleted.
Interest on unutilised government grant deposits was not taxable where the grant terms and accounts showed the funds and accrued interest belonged to the Government and the assessee remained only a custodian; the addition was deleted. TDS credit was not denied merely because the related interest was not taxable in the assessee's hands, as Rule 37BA credits tax to the deductee shown by the deductor, subject only to verification against any double claim; the matter was restored for that limited purpose. For MAT, interest on unutilised grant deposits and belated provident fund payment could not be added back unless covered by Explanation 1 to section 115JB, so those adjustments were deleted, while the provision for obsolete material was remitted for factual verification as to whether it was a provision or ascertained liability. Interest under section 234A could not be levied by reference to a revised return, because the provision applies only to delay in the original return; the levy was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
