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Business upkeep expenses despite no revenue, director's interest-free advances, and property gift additions-disallowances and notional interest deleted
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Indirect business expenditure comprising statutory audit fees, rent, rates and taxes, professional charges and property maintenance was held allowable under s.37(1) as necessary to maintain corporate existence and incurred wholly for business purposes despite no revenue in the year; the disallowance was rejected. Notional interest on interest-free advances to a director was deleted since the advances were old, funded from share capital/free reserves, no interest-bearing funds were used, and only real income is taxable; the addition was unsustainable. Protective addition relating to a property gift was set aside because the assessee had already made and accepted a substantive addition in the subsequent year, rendering protective assessment unwarranted; the Revenue's appeal was dismissed. - ITAT
Indirect business expenditure comprising statutory audit fees, rent, rates and taxes, professional charges and property maintenance was held allowable under s.37(1) as necessary to maintain corporate existence and incurred wholly for business purposes despite no revenue in the year; the disallowance was rejected. Notional interest on interest-free advances to a director was deleted since the advances were old, funded from share capital/free reserves, no interest-bearing funds were used, and only real income is taxable; the addition was unsustainable. Protective addition relating to a property gift was set aside because the assessee had already made and accepted a substantive addition in the subsequent year, rendering protective assessment unwarranted; the Revenue's appeal was dismissed. - ITAT
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