Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
The assessee claimed deduction for compensation paid to farmers for acquiring mining rights, which was an allowable expenditure. The Assessing Officer allowed the expenditure over 20 years and made an addition. The CIT(A) allowed the assessee's appeal, relying on the Supreme Court's decision in M/s Reliance Petro Products Pvt. Ltd., holding that it was not a case of furnishing inaccurate particulars of income, and penalty u/s 271(1)(c) of the Income Tax Act was not leviable. The assessee did not furnish inaccurate particulars, and the expenditure was allowed on a deferred basis. The ITAT, in Simplex Pharma (P) Ltd. and Onicra Credit Rating Agency of India Ltd., had deleted the penalty levied u/s 271(1)(c) on deferred revenue expenditure. The ITAT concurred with the CIT(A)'s findings and dismissed the revenue's ground.
The assessee claimed deduction for compensation paid to farmers for acquiring mining rights, which was an allowable expenditure. The Assessing Officer allowed the expenditure over 20 years and made an addition. The CIT(A) allowed the assessee's appeal, relying on the Supreme Court's decision in M/s Reliance Petro Products Pvt. Ltd., holding that it was not a case of furnishing inaccurate particulars of income, and penalty u/s 271(1)(c) of the Income Tax Act was not leviable. The assessee did not furnish inaccurate particulars, and the expenditure was allowed on a deferred basis. The ITAT, in Simplex Pharma (P) Ltd. and Onicra Credit Rating Agency of India Ltd., had deleted the penalty levied u/s 271(1)(c) on deferred revenue expenditure. The ITAT concurred with the CIT(A)'s findings and dismissed the revenue's ground.
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