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...
In an abated search assessment under section 153A, the return filed in response to the search notice substituted the earlier return, so the assessee could make a fresh or altered claim and the Revenue could not apply reassessment principles; the lease rentals from the IT park/SEZ were accepted as business income in line with the CBDT circular and past departmental acceptance. On disallowance under section 14A, the Tribunal sustained restriction of the disallowance under normal provisions to exempt income and upheld that section 14A read with Rule 8D could not be mechanically applied for book profit computation, subject to direct expenditure. The notional annual letting value of unsold stock-in-trade was deleted because section 23(5) operated only prospectively from assessment year 2018-19.
In an abated search assessment under section 153A, the return filed in response to the search notice substituted the earlier return, so the assessee could make a fresh or altered claim and the Revenue could not apply reassessment principles; the lease rentals from the IT park/SEZ were accepted as business income in line with the CBDT circular and past departmental acceptance. On disallowance under section 14A, the Tribunal sustained restriction of the disallowance under normal provisions to exempt income and upheld that section 14A read with Rule 8D could not be mechanically applied for book profit computation, subject to direct expenditure. The notional annual letting value of unsold stock-in-trade was deleted because section 23(5) operated only prospectively from assessment year 2018-19.
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