Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Dominant issue: whether the taxpayer could claim the new tax regime under section 115BAC despite delayed filing of Form 10-IE and a slightly late return. Reasoning: while jurisprudence treats late Form 10-IE as a procedural lapse that ordinarily should not forfeit the new regime, the return itself was filed late, rendering the new-regime option infirm and requiring reassessment under the old regime. Outcome: matter remanded to the Assessing Officer to admit and verify alternative claims for deductions under sections 80C and 80TTA and grant relief if substantiated; appeal allowed for statistical purposes. - ITAT
Dominant issue: whether the taxpayer could claim the new tax regime under section 115BAC despite delayed filing of Form 10-IE and a slightly late return. Reasoning: while jurisprudence treats late Form 10-IE as a procedural lapse that ordinarily should not forfeit the new regime, the return itself was filed late, rendering the new-regime option infirm and requiring reassessment under the old regime. Outcome: matter remanded to the Assessing Officer to admit and verify alternative claims for deductions under sections 80C and 80TTA and grant relief if substantiated; appeal allowed for statistical purposes. - ITAT
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