S. 14A : Disallowance of expenditure – Exempt income –Disallowances can be made only where the AO recorded his satisfaction as to how the claim of the Assessee that no expenditure was incurred to earn exempt income is incorrect. [R. 8D]
S. 14A : Disallowance of expenditure – Exempt income –Disallowances can be made only where the AO recorded his satisfaction as to how the claim of the Assessee that no expenditure was incurred to earn exempt income is incorrect. [R. 8D]
S. 14A : Disallowance of expenditure – Exempt income –Provision would not apply where no exempt income was received or receivable during relevant previous year by assessee. [R. 8D ]
S. 5 : Scope of total income -Accrual- Interest on Government securities which has become due and payable alone can be considered as accrued and taxable. [S. 28(i), 145]
S. 4 : Charge of Income tax – Capital or revenue -Subsidy received from Government for setting up of an industry in the backward area was to be treated as a capital receipt.
S. 4 : Charge of income-tax – Compensation received by the assesse in lieu of withdrawal of criminal complaint filed against a person for impersonation and forging Assessee’s signature on a document relating to sale of shares of a company is not taxable as income. [S. 2(24)]
S. 271(1)(c) : Penalty – Concealment – Capital gains- Cost of acquisition- In case of inadvertent mistake in computation of income by assessee, no penalty can be imposed for furnishing inaccurate particulars of income. [ S.45 ]
S. 271(1)(c) : Penalty – Concealment –Notional income- Where addition/disallowance made by AO is not free from doubts and debates, no penalty can be imposed.
S. 253 : Appellate Tribunal –Oral ground – Jurisdiction- Where there being no occasion for CIT(A) to decide a particular issue against assesse, assesse cannot support the impugned order under rule 27 on that ground. [S.271(1) (c ), R.27]
S. 147 : Reassessment – Within four years – Reopening of assessment based only on the change of opinion on the existing material cannot be sustained in absence of any new tangible material.
S. 145 : Method of accounting – If AO accepted books of accounts in preceding and subsequent years – rejection of books based on hypothetical calculations was not justified.