Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Ad hoc capitalization of advertisement, publicity and sales promotion expenditure was found unsustainable because no tangible basis showed creation of a capital asset or brand-building benefit; the expenditure remained revenue in nature. TDS credit was held to follow the income actually offered to tax under the contract period, so a mismatch between TDS reflected and income assessable in the year could not justify an addition where section 199(3) and Rule 37BA(3)(i) were correctly applied. Interest under section 244A was not taxable on accrual basis because income accrues only when there is an enforceable right to receive it, and the amount had not actually become receivable in the relevant year.
Ad hoc capitalization of advertisement, publicity and sales promotion expenditure was found unsustainable because no tangible basis showed creation of a capital asset or brand-building benefit; the expenditure remained revenue in nature. TDS credit was held to follow the income actually offered to tax under the contract period, so a mismatch between TDS reflected and income assessable in the year could not justify an addition where section 199(3) and Rule 37BA(3)(i) were correctly applied. Interest under section 244A was not taxable on accrual basis because income accrues only when there is an enforceable right to receive it, and the amount had not actually become receivable in the relevant year.
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