Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Peak credit theory was applied to unexplained advances for land purchase, and the additional addition was deleted because the issue was already covered by the assessee's earlier years. Disallowance under section 40(a)(ia) was removed where the lender had already recorded the interest and paid tax, so no default by the assessee was found. On job work receipts, only the income component was taxable and the 12 per cent profit estimate was sustained. Cash advances for land purchase did not attract section 40A(3) because they were advances, not claimed expenditure. Restricted interest disallowance under section 36(1)(iii) was upheld for unexplained advances. Artificially inflated work-in-progress based on survey surrender was reduced to avoid a future deduction for expenditure never incurred.
Peak credit theory was applied to unexplained advances for land purchase, and the additional addition was deleted because the issue was already covered by the assessee's earlier years. Disallowance under section 40(a)(ia) was removed where the lender had already recorded the interest and paid tax, so no default by the assessee was found. On job work receipts, only the income component was taxable and the 12 per cent profit estimate was sustained. Cash advances for land purchase did not attract section 40A(3) because they were advances, not claimed expenditure. Restricted interest disallowance under section 36(1)(iii) was upheld for unexplained advances. Artificially inflated work-in-progress based on survey surrender was reduced to avoid a future deduction for expenditure never incurred.
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