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...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Notional partners' capital entries credited as receivable under an LLP agreement were held outside section 68 because there was no actual inflow of funds during the year, the entries were only book adjustments, and the partners' identities and creditworthiness were not materially disputed; the addition was deleted. Administrative expenditure was also allowed because the LLP had already been set up through execution of the agreement, bank account opening, professional engagement, and regulatory steps, so business expenses remained deductible even without revenue. The Tribunal therefore upheld deletion of both the section 68 addition and the disallowance of administrative expenditure and dismissed the Revenue's appeal.
Notional partners' capital entries credited as receivable under an LLP agreement were held outside section 68 because there was no actual inflow of funds during the year, the entries were only book adjustments, and the partners' identities and creditworthiness were not materially disputed; the addition was deleted. Administrative expenditure was also allowed because the LLP had already been set up through execution of the agreement, bank account opening, professional engagement, and regulatory steps, so business expenses remained deductible even without revenue. The Tribunal therefore upheld deletion of both the section 68 addition and the disallowance of administrative expenditure and dismissed the Revenue's appeal.
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