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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
