Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
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ITAT held that actual contractual rent under registered leave-and-license arrangements, together with separately agreed commercial amenity charges, could not be replaced by an enhanced annual letting value absent cogent material of suppressed rent, sham transactions, or unaccounted consideration; the addition under section 23(1)(a) was deleted. It also held that interest on borrowed capital used to acquire let-out commercial property was deductible under section 24(b) because the borrowings had a direct nexus with acquisition and the Revenue could not deny relief while taxing the property under the head income from house property; the disallowance was deleted. In the absence of exempt income, section 14A and Rule 8D could not be invoked, and the Finance Act 2022 Explanation was treated as prospective.
ITAT held that actual contractual rent under registered leave-and-license arrangements, together with separately agreed commercial amenity charges, could not be replaced by an enhanced annual letting value absent cogent material of suppressed rent, sham transactions, or unaccounted consideration; the addition under section 23(1)(a) was deleted. It also held that interest on borrowed capital used to acquire let-out commercial property was deductible under section 24(b) because the borrowings had a direct nexus with acquisition and the Revenue could not deny relief while taxing the property under the head income from house property; the disallowance was deleted. In the absence of exempt income, section 14A and Rule 8D could not be invoked, and the Finance Act 2022 Explanation was treated as prospective.
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