Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Non-debit of partners' remuneration and interest did not affect eligibility for deduction under section 10AA where the resulting business profit remained eligible, so the deletion of the addition was justified. The note also records that reassessment cannot travel beyond the recorded reasons: reopening was based on discrepancy in import figures, no addition was made on that issue, and the addition on partners' remuneration and interest was outside the permissible scope. The Revenue's appeal was dismissed on both grounds.
Non-debit of partners' remuneration and interest did not affect eligibility for deduction under section 10AA where the resulting business profit remained eligible, so the deletion of the addition was justified. The note also records that reassessment cannot travel beyond the recorded reasons: reopening was based on discrepancy in import figures, no addition was made on that issue, and the addition on partners' remuneration and interest was outside the permissible scope. The Revenue's appeal was dismissed on both grounds.
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