Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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ITAT adjudicated multiple taxation issues involving property-related income and interest deductions. The tribunal held that: (1) reassessment notice issued to a non-existing entity was null and void, quashing the re-assessment order; (2) pre-construction interest deduction under Section 24(b) was allowable for the entire Rs. 30 Crore loan utilized for property acquisition, rejecting proportionate disallowance; (3) maintenance charges from lessees were correctly classified as business income; and (4) loan substitution for property acquisition was acceptable, permitting interest deduction when nexus between loan and property was established. The tribunal ultimately confirmed the lower appellate authority's order in favor of the assessee.
ITAT adjudicated multiple taxation issues involving property-related income and interest deductions. The tribunal held that: (1) reassessment notice issued to a non-existing entity was null and void, quashing the re-assessment order; (2) pre-construction interest deduction under Section 24(b) was allowable for the entire Rs. 30 Crore loan utilized for property acquisition, rejecting proportionate disallowance; (3) maintenance charges from lessees were correctly classified as business income; and (4) loan substitution for property acquisition was acceptable, permitting interest deduction when nexus between loan and property was established. The tribunal ultimately confirmed the lower appellate authority's order in favor of the assessee.
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