Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
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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