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...
Cash expenditure was disallowed under section 40A(3) because the assessee failed to substantiate the claimed Rule 6DD exception with supporting ledger accounts or confirmation from the payee. The Tribunal noted that the assessee had dealt with the payee and that most payments were made in cash, so the case did not fall within the statutory exception. The disallowance was therefore upheld for the lead year and applied to the remaining assessment years, with all four appeals dismissed.
Cash expenditure was disallowed under section 40A(3) because the assessee failed to substantiate the claimed Rule 6DD exception with supporting ledger accounts or confirmation from the payee. The Tribunal noted that the assessee had dealt with the payee and that most payments were made in cash, so the case did not fall within the statutory exception. The disallowance was therefore upheld for the lead year and applied to the remaining assessment years, with all four appeals dismissed.
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