Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Rule 86A is confined to blocking input tax credit only up to the credit available in the electronic credit ledger and does not authorise negative blocking. The text notes that the power must be exercised only after satisfying the statutory preconditions, including a reason to believe and recorded reasons, because otherwise the invocation is vulnerable to challenge on natural justice grounds. Applying that position, the impugned blocking beyond the available balance was held unsustainable, and restoration by unblocking to the extent blocked was directed, while all other issues were kept open.
Rule 86A is confined to blocking input tax credit only up to the credit available in the electronic credit ledger and does not authorise negative blocking. The text notes that the power must be exercised only after satisfying the statutory preconditions, including a reason to believe and recorded reasons, because otherwise the invocation is vulnerable to challenge on natural justice grounds. Applying that position, the impugned blocking beyond the available balance was held unsustainable, and restoration by unblocking to the extent blocked was directed, while all other issues were kept open.
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