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...
Weighted deduction for research and development was confined to expenditure approved by the prescribed authority, but the unapproved revenue outlay retained its character as business expenditure and was allowed under general deduction principles. The Tribunal also applied the presumption that investments were made from interest-free funds where own funds exceeded investments, so the interest component of the exempt-income disallowance was deleted and the balance was to be recomputed only against investments yielding exempt income. Rent paid to related parties for a farmhouse was only partly supported by business use, so the disallowance was restricted to 50%.
Weighted deduction for research and development was confined to expenditure approved by the prescribed authority, but the unapproved revenue outlay retained its character as business expenditure and was allowed under general deduction principles. The Tribunal also applied the presumption that investments were made from interest-free funds where own funds exceeded investments, so the interest component of the exempt-income disallowance was deleted and the balance was to be recomputed only against investments yielding exempt income. Rent paid to related parties for a farmhouse was only partly supported by business use, so the disallowance was restricted to 50%.
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