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...
Expenditure incurred by a society on garba and advertisement was treated as connected with its cultural, social and educational objects, and the mere fact that payments were made to group concerns or that the activity resulted in a loss did not justify disallowance. The Tribunal found no material showing sham, bogus or object-unrelated expenditure, and noted that the authorities had not rejected the books of account under section 145(3) or identified any express defect in the tax audit report. Applying commercial expediency, it held that the tax authorities could not substitute their view for the assessee's business judgment. The loss disallowance was deleted and the appeal was allowed.
Expenditure incurred by a society on garba and advertisement was treated as connected with its cultural, social and educational objects, and the mere fact that payments were made to group concerns or that the activity resulted in a loss did not justify disallowance. The Tribunal found no material showing sham, bogus or object-unrelated expenditure, and noted that the authorities had not rejected the books of account under section 145(3) or identified any express defect in the tax audit report. Applying commercial expediency, it held that the tax authorities could not substitute their view for the assessee's business judgment. The loss disallowance was deleted and the appeal was allowed.
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