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Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The ITAT quashed reassessment notices u/s 148 for AY 2014-15 and 2016-17 as time-barred, finding the notices were issued beyond the prescribed limitation period. The tribunal held that interest expenditure incurred for business purposes must be fully deducted in the year of expenditure, rejecting the AO's attempt to apportion interest between sales and work-in-progress. Applying the percentage of completion method and relying on ICDS IX provisions, the tribunal concluded that once development plans are obtained and units can be sold, interest capitalization ceases. The tribunal emphasized that when ICDS provisions conflict with the Income Tax Act, the Act's provisions prevail. Consequently, the revenue's appeal was dismissed, allowing the full interest expenditure deduction for the assessee.
The ITAT quashed reassessment notices u/s 148 for AY 2014-15 and 2016-17 as time-barred, finding the notices were issued beyond the prescribed limitation period. The tribunal held that interest expenditure incurred for business purposes must be fully deducted in the year of expenditure, rejecting the AO's attempt to apportion interest between sales and work-in-progress. Applying the percentage of completion method and relying on ICDS IX provisions, the tribunal concluded that once development plans are obtained and units can be sold, interest capitalization ceases. The tribunal emphasized that when ICDS provisions conflict with the Income Tax Act, the Act's provisions prevail. Consequently, the revenue's appeal was dismissed, allowing the full interest expenditure deduction for the assessee.
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