S.147: Reassessment —With in four years -Cash credit — Capital – Partner- Return was not filed – No specific direction by CIT(A)- Notice for reassessment was held to be valid . [ S.68, 148 ]
S.147: Reassessment —With in four years -Cash credit — Capital – Partner- Return was not filed – No specific direction by CIT(A)- Notice for reassessment was held to be valid . [ S.68, 148 ]
S.147:Reassessment –With in four years-Change of opinion- Block assessment -Notice to reassess amount discovered during post search enquiries is held to be not valid . [ S.132,148, 158BC ]
S. 145A : Method of accounting – Valuation -Stock- Trading in shares — Valuation of shares according to net realisable value is held to be justified .[S.145(2) ]
S. 80-O : Royalties – Foreign enterprises -Fees for technical services rendered to foreign entity — Explanation added with effect from 1-4-1992 — Fees for services rendered in India- Not entitled to deduction – Principle of consistency or doctrine of precedents would not apply when there is change in law.
S. 80IC : Special category States -Initial Assessment Year —Substantial expansion- Claimed 100% deduction for five years- Cannot claim deduction at 100 Per Cent. beyond period of five years on ground of substantial expansion.
S. 45(4) : Capital gains – Distribution of capital asset – Dissolution of firm -Change in constitution of firm -Retirement of some partners and induction of new partners — No revaluation of assets — Businesses continued — Firm reconstituted and not dissolved-Not liable to pay capital gains tax . [ S. 45,187(2) ]
S.37 (1): Business expenditure —Travelling expenditure of wife of Company’s Senior Executive accompanying him abroad for his medical treatment — Expenditure is held to be not allowable . [ S.264 ]
S. 36(1)(iii) :Interest on borrowed capital -Commercial expediency – Interest free advance to third parties -Interest paid is held to be allowable as deduction .
S. 11 : Property held for charitable purposes – Accumulation of income- Explanation of purposes for which funds accumulated was furnished during course of assessment proceedings is a sufficient compliance . [ S.11(2), form No 10 ]
S. 10 (23C): Educational institution- Registration u/s 12AA is not mandatory to claim exemption.[ S.12AA, 10 (23C(iiiad)]