Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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In this ITAT decision, the tribunal addressed two key issues:...
Property Sale Valuation and Interest Expense Deduction Upheld: Fair Market Value Assessment Supports Taxpayer's Claims Under Sections 43CA and 36(1)(iii)
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In this ITAT decision, the tribunal addressed two key issues: (1) valuation of property sale and (2) nature of interest expenses. Regarding property sale under Section 43CA, the tribunal held that the sale consideration declared by the assessee (Rs. 28.82 Cr with Rs. 6.19 Cr interest) was acceptable, as the fair market value determined by DVO (Rs. 37.45 Cr) differed by less than 10%. The tribunal rejected additional tax demands, finding the assessee's declared value valid. For conversion charges, the tribunal classified interest expenses as revenue expenditure under Section 36(1)(iii), noting the asset was put to use after capitalization. Consequently, the ITAT dismissed the revenue's appeals, affirming the assessee's tax treatment for both issues.
In this ITAT decision, the tribunal addressed two key issues: (1) valuation of property sale and (2) nature of interest expenses. Regarding property sale under Section 43CA, the tribunal held that the sale consideration declared by the assessee (Rs. 28.82 Cr with Rs. 6.19 Cr interest) was acceptable, as the fair market value determined by DVO (Rs. 37.45 Cr) differed by less than 10%. The tribunal rejected additional tax demands, finding the assessee's declared value valid. For conversion charges, the tribunal classified interest expenses as revenue expenditure under Section 36(1)(iii), noting the asset was put to use after capitalization. Consequently, the ITAT dismissed the revenue's appeals, affirming the assessee's tax treatment for both issues.
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