Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Approved gratuity fund contributions adjusted against earlier excess payments were held not to be unpaid provisions, and the gratuity claim was allowable because the fund was approved. Lease-rental disallowance for non-deduction of tax was sustained for the year under appeal, with corresponding deduction allowed in the subsequent year in line with section 40(a)(ia). Short deduction of tax was also treated as falling within section 40(a)(ia), subject to proportionate restriction. Ind AS transition amount was held to be a statutory MAT adjustment, not prior period expense, and the related addition was deleted. Repairs and maintenance expenditure remained revenue in nature despite book capitalisation, and CSR expenditure could not be added back to book profit absent a specific adjustment under section 115JB.
Approved gratuity fund contributions adjusted against earlier excess payments were held not to be unpaid provisions, and the gratuity claim was allowable because the fund was approved. Lease-rental disallowance for non-deduction of tax was sustained for the year under appeal, with corresponding deduction allowed in the subsequent year in line with section 40(a)(ia). Short deduction of tax was also treated as falling within section 40(a)(ia), subject to proportionate restriction. Ind AS transition amount was held to be a statutory MAT adjustment, not prior period expense, and the related addition was deleted. Repairs and maintenance expenditure remained revenue in nature despite book capitalisation, and CSR expenditure could not be added back to book profit absent a specific adjustment under section 115JB.
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