Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
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The purpose test for subsidy receipts requires examination of the scheme's operative provisions rather than its nomenclature, source, form or payment timing. Electricity subsidy under the Pondicherry power subsidy scheme was payable after production and calculated as a percentage of actual energy charges. Because it directly reduced the cost of power used in manufacturing and was not linked or earmarked to capital expenditure or creation of a capital asset, it constituted operational assistance. The subsidy was therefore treated as a taxable revenue receipt rather than a capital receipt, and the appeal was dismissed.
The purpose test for subsidy receipts requires examination of the scheme's operative provisions rather than its nomenclature, source, form or payment timing. Electricity subsidy under the Pondicherry power subsidy scheme was payable after production and calculated as a percentage of actual energy charges. Because it directly reduced the cost of power used in manufacturing and was not linked or earmarked to capital expenditure or creation of a capital asset, it constituted operational assistance. The subsidy was therefore treated as a taxable revenue receipt rather than a capital receipt, and the appeal was dismissed.
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