Appeal dismissed: petitioner denied ITC for electricity used in township maintenance as residential supply; Explanation 1(d) prospective under s.2(17)...
Registration under section 12AA granted where substantive charitable objects for ex-servicemen, incidental commercial activity permitted and profits a...
The ITAT affirmed the appellate order deleting the impugned ad hoc disallowance made by the AO, holding that the AO had not impugned the genuineness of the expenses and had failed to appreciate their nexus with the assessee's business (including increased repair and maintenance following acquisition of two additional vessels and legitimate tour expenses). The Tribunal further sustained deletion of the proposed addition relating to alleged excess purchase value of vessels, finding the carrying value in the transferor's audited accounts duly substantiated, independent valuation unchallenged by the revenue, and recorded cost lower than original purchase price (with rupee devaluation affecting resultant cost); consequently no inflated cost or excess depreciation was established.
The ITAT affirmed the appellate order deleting the impugned ad hoc disallowance made by the AO, holding that the AO had not impugned the genuineness of the expenses and had failed to appreciate their nexus with the assessee's business (including increased repair and maintenance following acquisition of two additional vessels and legitimate tour expenses). The Tribunal further sustained deletion of the proposed addition relating to alleged excess purchase value of vessels, finding the carrying value in the transferor's audited accounts duly substantiated, independent valuation unchallenged by the revenue, and recorded cost lower than original purchase price (with rupee devaluation affecting resultant cost); consequently no inflated cost or excess depreciation was established.
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