Professional fees and foreign branch expenses incurred by a strategic investment company were allowable under Section 37(1) in the absence of any finding that the expenditure was excessive, unreasonable
The Supreme Court upheld the High Court’s quashing of a reassessment notice, holding that reopening based only on existing records was invalid and refusing to condone a 426-day delay.
High Court set aside reassessment proceedings after finding that the notice was based only on existing records, with no new material to justify reopening of the completed scrutiny assessment.
The appeal was dismissed solely on procedural grounds without hearing the assessee. The Tribunal held that the CIT(A) is duty-bound to decide appeals on merits after granting a proper opportunity.
The Tribunal examined whether Section 153A could be applied to the search year itself. It held that invoking Section 153A for the wrong assessment year was invalid, rendering the assessment void.
The Tribunal held that reopening after four years is invalid without alleging failure to disclose material facts. The reassessment was barred by the proviso to section 147.
The Tribunal held that rural agricultural land excluded from capital asset under Section 2(14) cannot be taxed under Section 56(2)(vii)(b). Addition based on stamp duty valuation was therefore deleted in full.
The Tribunal held that serving notices on an outdated email ID violates principles of natural justice. The assessment was set aside and the matter restored for fresh adjudication after proper service.
The authority ruled that carbon pultruded plates are not carbon fibre under the amended exemption notification and therefore cannot claim concessional duty as raw materials, clarifying the limited scope of the revised entry.
AAR Mumbai held that architecturally finished stainless steel wall panels retain the character of flat-rolled products and must be classified under Heading 7219, not as structural parts or miscellaneous articles.
