https://www.taxtmi.com/caselaws?id=363068 In section 153A proceedings, an addition for alleged unverified software purchases could not be sustained where the same disallowance had already been deleted in the regular assessment and no incriminating search material was found. The article also notes that a sales tax subsidy under the Haryana incentive scheme was tested by the purpose test and treated as a capital receipt because it was intended to encourage capital investment. The same subsidy issue, repeated in section 153A without search material, was therefore not sustainable as a revenue addition. The governing principle is that repeated additions lacking incriminating material cannot stand, and subsidy character depends on its predominant purpose. 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 In section 153A proceedings, an addition for alleged unverified software purchases could not be sustained where the same disallowance had already been deleted in the regular assessment and no incriminating search material was found. The article also notes that a sales tax subsidy under the Haryana incentive scheme was tested by the purpose test and treated as a capital receipt because it was intended to encourage capital investment. The same subsidy issue, repeated in section 153A without search material, was therefore not sustainable as a revenue addition. The governing principle is that repeated additions lacking incriminating material cannot stand, and subsidy character depends on its predominant purpose. Case-Laws Income Tax Thu, 05 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=363068