Road restoration charges constitute taxable services when requested for commercial pipeline activity, requiring reverse-charge GST from the business r...
Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
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Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
ITAT held that pre-operating expenses claimed by assessee as revenue expenditure were correctly disallowed. Tribunal established that mere nomenclature in books cannot determine expense allowability, applying precedents from India Discount Co. Ltd., Provincial Farmers Ltd., and KCP Ltd. Evidence demonstrated payments related to business expansion into new geographical areas before commercial exploitation, constituting capital expenditure. Regarding customer acquisition costs, ITAT sustained CIT(A)'s decision allowing 50% expenditure, recognizing revenue nature while applying amortization principle. Tribunal rejected assessee's argument for full deduction in current assessment year, upholding partial allowance approach for expenses benefiting future years despite assessee's non-election of amortization treatment.
ITAT held that pre-operating expenses claimed by assessee as revenue expenditure were correctly disallowed. Tribunal established that mere nomenclature in books cannot determine expense allowability, applying precedents from India Discount Co. Ltd., Provincial Farmers Ltd., and KCP Ltd. Evidence demonstrated payments related to business expansion into new geographical areas before commercial exploitation, constituting capital expenditure. Regarding customer acquisition costs, ITAT sustained CIT(A)'s decision allowing 50% expenditure, recognizing revenue nature while applying amortization principle. Tribunal rejected assessee's argument for full deduction in current assessment year, upholding partial allowance approach for expenses benefiting future years despite assessee's non-election of amortization treatment.
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TaxTMI 
TaxTMI 
of 4920 
