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Issues: (i) Whether the addition made while processing the return under section 143(1) in respect of enhanced compensation received on compulsory acquisition of agricultural land was liable to be sustained; (ii) whether the addition made in respect of interest received on enhanced compensation required factual verification and recomputation; (iii) whether deduction under section 80GGB on political contribution could be restricted to 7.5% of average net profits in view of the amendment to section 182 of the Companies Act, 2013.
Issue (i): Whether the addition made while processing the return under section 143(1) in respect of enhanced compensation received on compulsory acquisition of agricultural land was liable to be sustained.
Analysis: The enhanced compensation was claimed as exempt, and the record indicated that the amount was reflected under an incorrect head due to an inadvertent clerical error. On that basis, the addition made in processing the return required reconsideration and the income had to be recomputed after proper verification of the claim.
Conclusion: The issue was restored to the Assessing Officer for recomputation, in favour of the assessee.
Issue (ii): Whether the addition made in respect of interest received on enhanced compensation required factual verification and recomputation.
Analysis: The nature of the interest received on enhanced compensation, including its treatment under the land acquisition provisions and its taxability, depended on verification of the relevant facts. The matter therefore could not be finally decided without examining the character of the receipt and the manner in which it was offered to tax.
Conclusion: The issue was restored to the Assessing Officer for verification and recomputation, in favour of the assessee.
Issue (iii): Whether deduction under section 80GGB on political contribution could be restricted to 7.5% of average net profits in view of the amendment to section 182 of the Companies Act, 2013.
Analysis: The restriction was examined against the statutory scheme of section 80GGB and the amendment brought in section 182 of the Companies Act, 2013. In view of the amended legal position, the allowable deduction required fresh verification of the contribution actually made and consequential recomputation according to law.
Conclusion: The issue was restored to the Assessing Officer for verification and recomputation, in favour of the assessee.
Final Conclusion: The matter required fresh examination at the assessment stage on the identified issues, and the appellate relief granted was consequential to such restoration rather than a final affirmation of the additions.
Ratio Decidendi: Where the correctness of an addition or the quantum of deduction depends on verification of facts or application of an amended statutory regime, the matter may be restored for recomputation instead of being finally sustained on the existing record.
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