Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Whether waiver of non-convertible debentures constituted taxable revenue receipt under s.28(iv) or required inclusion under s.41(1): relying on SC precedent that s.28(iv) does not apply to monetary receipts and on record showing the instrument was borrowing with no interest charged to P&L, the waiver is not exigible under s.28(iv) or s.41(1); addition of Rs.75 lakh is deleted. Whether carried forward business losses and unabsorbed depreciation were allowable: return schedules (CFL and UD) substantiate claimed carryforwards and AO/CIT(A) offered no valid rebuttal, so carryforward losses and unabsorbed depreciation must be allowed. - ITAT
Whether waiver of non-convertible debentures constituted taxable revenue receipt under s.28(iv) or required inclusion under s.41(1): relying on SC precedent that s.28(iv) does not apply to monetary receipts and on record showing the instrument was borrowing with no interest charged to P&L, the waiver is not exigible under s.28(iv) or s.41(1); addition of Rs.75 lakh is deleted. Whether carried forward business losses and unabsorbed depreciation were allowable: return schedules (CFL and UD) substantiate claimed carryforwards and AO/CIT(A) offered no valid rebuttal, so carryforward losses and unabsorbed depreciation must be allowed. - ITAT
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