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...
Characterisation of receipts turned on the nature of the assessee's activities and services, not mere ownership or leases; where letting is accompanied by systematic provision of amenities and operational facilities, such receipts constitute income from business or profession. Reliance on Supreme Court precedents applying the nature of activity test supported treating rental receipts as business income. Prior assessments accepting the same treatment invoked the principle of consistency, reinforcing classification as business income rather than income from house property. Decision went against the revenue.
Characterisation of receipts turned on the nature of the assessee's activities and services, not mere ownership or leases; where letting is accompanied by systematic provision of amenities and operational facilities, such receipts constitute income from business or profession. Reliance on Supreme Court precedents applying the nature of activity test supported treating rental receipts as business income. Prior assessments accepting the same treatment invoked the principle of consistency, reinforcing classification as business income rather than income from house property. Decision went against the revenue.
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