Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
The issue pertained to determining the commencement date of business operations for the purpose of claiming deduction u/s 35D of the Act for preliminary expenses incurred prior to the commencement of business. The assessee had deducted provident fund from June 2008 onwards, indicating the commencement of business operations from that date. The Assessing Officer, however, contended that the business commenced only upon acquisition of the equity research unit under a slump sale agreement. The CIT(A) ruled in favor of the assessee, and the ITAT upheld the CIT(A)'s finding, dismissing the Revenue's appeal. The critical issue was the determination of the appropriate commencement date for claiming deduction u/s 35D, with the ITAT accepting the assessee's claim based on the evidence presented.
The issue pertained to determining the commencement date of business operations for the purpose of claiming deduction u/s 35D of the Act for preliminary expenses incurred prior to the commencement of business. The assessee had deducted provident fund from June 2008 onwards, indicating the commencement of business operations from that date. The Assessing Officer, however, contended that the business commenced only upon acquisition of the equity research unit under a slump sale agreement. The CIT(A) ruled in favor of the assessee, and the ITAT upheld the CIT(A)'s finding, dismissing the Revenue's appeal. The critical issue was the determination of the appropriate commencement date for claiming deduction u/s 35D, with the ITAT accepting the assessee's claim based on the evidence presented.
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