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...
Rule 7B, not the general composite-income rule, governs income from coffee grown and processed by the seller; for self-grown coffee, 40% is taxable as business income and 60% retains agricultural character. The ITAT accepted that the assessee also purchased coffee from other planters and processed and sold it, but Rule 7B did not extend to that purchased coffee in the same manner. The matter was therefore remanded to the Assessing Officer for fresh computation after segregating income from the assessee's own coffee estate from income arising on purchased coffee, with agricultural exemption available only to the self-grown produce.
Rule 7B, not the general composite-income rule, governs income from coffee grown and processed by the seller; for self-grown coffee, 40% is taxable as business income and 60% retains agricultural character. The ITAT accepted that the assessee also purchased coffee from other planters and processed and sold it, but Rule 7B did not extend to that purchased coffee in the same manner. The matter was therefore remanded to the Assessing Officer for fresh computation after segregating income from the assessee's own coffee estate from income arising on purchased coffee, with agricultural exemption available only to the self-grown produce.
Note: It is a system-generated summary and is for quick reference only.