Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
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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