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...
Issue: Whether interest under section 234A is leviable where the original return was belated but a return filed in response to a section 153C notice was timely. Reasoning: Section 234A(1) charges interest for delay in filing the original return based on tax as determined under section 143(1) or a regular assessment; Explanation 3 treats an assessment made for the first time under section 153A (including assessments pursuant to section 153C) as a regular assessment for section 234A purposes. Outcome: Interest under section 234A was correctly computed and sustained. - ITAT
Issue: Whether interest under section 234A is leviable where the original return was belated but a return filed in response to a section 153C notice was timely. Reasoning: Section 234A(1) charges interest for delay in filing the original return based on tax as determined under section 143(1) or a regular assessment; Explanation 3 treats an assessment made for the first time under section 153A (including assessments pursuant to section 153C) as a regular assessment for section 234A purposes. Outcome: Interest under section 234A was correctly computed and sustained. - ITAT
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