https://www.taxtmi.com/caselaws?id=363068 Section 153A assessments cannot sustain additions for alleged unverified software purchases or sales tax subsidy where the same matters were deleted on merits in regular assessment proceedings and no incriminating search material supports their reintroduction. Sales tax subsidy linked to an industrial incentive scheme is characterised through the purpose test; where its predominant purpose is to encourage capital investment, it constitutes a capital receipt rather than revenue income. Consistency supports retaining the earlier treatment of the subsidy. The stated analysis requires deletion of both additions in the absence of search-based material. en-us Thu, 05 Jul 2018 00:00:00 +0530 Sat, 07 Jul 2018 08:16:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=363068 Section 153A assessments cannot sustain additions for alleged unverified software purchases or sales tax subsidy where the same matters were deleted on merits in regular assessment proceedings and no incriminating search material supports their reintroduction. Sales tax subsidy linked to an industrial incentive scheme is characterised through the purpose test; where its predominant purpose is to encourage capital investment, it constitutes a capital receipt rather than revenue income. Consistency supports retaining the earlier treatment of the subsidy. The stated analysis requires deletion of both additions in the absence of search-based material. Case-Laws Income Tax Thu, 05 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=363068