Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Assessees treatment of project selling costs under the percentage completion method conformed with ICAI guidance; advertising, promotion and commission expenses were allowable as revenue expenditure since revenue recognition threshold was not met. Interest on debentures financing the project must be capitalized; AO directed to disallow interest expense claimed without nexus to other uses. Debenture issue expenditure held allowable as borrowing cost. Notional interest on interest-free advances to related parties to be recalculated using assessees cost of capital and cannot increase claimed interest; AO to restrict adjustment to actual claimed interest. Section 14A adjustment partly allowed; TDS disallowance deleted due to excess timely deposit and AOs reverse calculation rejected.
Assessees treatment of project selling costs under the percentage completion method conformed with ICAI guidance; advertising, promotion and commission expenses were allowable as revenue expenditure since revenue recognition threshold was not met. Interest on debentures financing the project must be capitalized; AO directed to disallow interest expense claimed without nexus to other uses. Debenture issue expenditure held allowable as borrowing cost. Notional interest on interest-free advances to related parties to be recalculated using assessees cost of capital and cannot increase claimed interest; AO to restrict adjustment to actual claimed interest. Section 14A adjustment partly allowed; TDS disallowance deleted due to excess timely deposit and AOs reverse calculation rejected.
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