Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
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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