Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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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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