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...
Notional carry forward of depreciation losses that were previously set off against other income cannot be notionally brought forward to compute the deduction under section 80IA, because section 80IA(5) contains no mandate for such notional setoff; consequence: such earlier-absorbed losses are excluded when computing the 80IA deduction. Separately, section 80IA(9) prevents double claiming of deductions so that deductions under other Chapter VIA provisions remain computable but their combined allowability with 80IA is capped at 100% of business profits; CBDT guidance supports this limiting effect to prevent repeated deductions.
Notional carry forward of depreciation losses that were previously set off against other income cannot be notionally brought forward to compute the deduction under section 80IA, because section 80IA(5) contains no mandate for such notional setoff; consequence: such earlier-absorbed losses are excluded when computing the 80IA deduction. Separately, section 80IA(9) prevents double claiming of deductions so that deductions under other Chapter VIA provisions remain computable but their combined allowability with 80IA is capped at 100% of business profits; CBDT guidance supports this limiting effect to prevent repeated deductions.
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