Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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Interest arising from State Government funds advanced to an assessee is not taxable in the assessee's hands where the interest belongs to the State Government, including where the same issue has been determined for an earlier assessment year. Conversely, a signature bonus received on transferring developed power projects constitutes a revenue receipt when developing and transferring such projects forms part of the taxpayer's ordinary business and involves expenditure on surveys, testing and approvals. The distinction turns on beneficial ownership of the interest and the receipt's direct connection with regular business operations.
Interest arising from State Government funds advanced to an assessee is not taxable in the assessee's hands where the interest belongs to the State Government, including where the same issue has been determined for an earlier assessment year. Conversely, a signature bonus received on transferring developed power projects constitutes a revenue receipt when developing and transferring such projects forms part of the taxpayer's ordinary business and involves expenditure on surveys, testing and approvals. The distinction turns on beneficial ownership of the interest and the receipt's direct connection with regular business operations.
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