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...
Quantification of weighted deduction under section 35(2AB) depended on the expenditure approved in Form 3CL, not on the assessee's basic eligibility for the deduction. The Tribunal held that Form 3CL had already been sent to the jurisdictional Assessing Officer and therefore could not be rejected as additional evidence in rectification proceedings. Reading Rule 6(7A) for the relevant assessment year, the Assessing Officer was required to take cognizance of the approved expenditure and recompute the deduction accordingly. The impugned order was set aside and the issue was restored for fresh quantification after giving the assessee a reasonable opportunity of hearing.
Quantification of weighted deduction under section 35(2AB) depended on the expenditure approved in Form 3CL, not on the assessee's basic eligibility for the deduction. The Tribunal held that Form 3CL had already been sent to the jurisdictional Assessing Officer and therefore could not be rejected as additional evidence in rectification proceedings. Reading Rule 6(7A) for the relevant assessment year, the Assessing Officer was required to take cognizance of the approved expenditure and recompute the deduction accordingly. The impugned order was set aside and the issue was restored for fresh quantification after giving the assessee a reasonable opportunity of hearing.
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