Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
DSIR certification supported deduction under section 35(2AB) because the Tribunal applied judicial consistency and held that the Assessing Officer could not disregard the certified R&D expenditure without following the statutory procedure. It also sustained deletion of manufacturing-expense and R&D additions made on post-survey extrapolation, finding no abnormality in the expense ratio and no rebuttal of the factual findings. As those disallowances failed on merits, the reassessment based on the same grounds was held invalid. For the later year, interest disallowance linked to a loan treated as unexplained cash credit was deleted once that underlying addition no longer survived, while other claims were sent back for factual verification.
DSIR certification supported deduction under section 35(2AB) because the Tribunal applied judicial consistency and held that the Assessing Officer could not disregard the certified R&D expenditure without following the statutory procedure. It also sustained deletion of manufacturing-expense and R&D additions made on post-survey extrapolation, finding no abnormality in the expense ratio and no rebuttal of the factual findings. As those disallowances failed on merits, the reassessment based on the same grounds was held invalid. For the later year, interest disallowance linked to a loan treated as unexplained cash credit was deleted once that underlying addition no longer survived, while other claims were sent back for factual verification.
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