Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
ITAT held that where interest on unsecured loans was genuinely incurred for business purposes, the dispute could be confined only to the year of allowability under the mercantile system. As no finding was recorded that the interest was bogus, non-business, or lacking bona fides, disallowance of the portion claimed in the relevant year could not be sustained merely because it might be deductible in the next year. Shifting the deduction period was treated as revenue neutral, and the addition for alleged excess interest expenditure was deleted.
ITAT held that where interest on unsecured loans was genuinely incurred for business purposes, the dispute could be confined only to the year of allowability under the mercantile system. As no finding was recorded that the interest was bogus, non-business, or lacking bona fides, disallowance of the portion claimed in the relevant year could not be sustained merely because it might be deductible in the next year. Shifting the deduction period was treated as revenue neutral, and the addition for alleged excess interest expenditure was deleted.
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