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...
Assessment of income on account of unsubstantiated purchases was affirmed where the assessee failed to produce parties, documents or reconcile sundry balances; the tribunal upheld CIT(A)/NFAC direction to adopt a reasonable profit rate (informed by but not applying section 44AD) instead of disallowing all purchases. Separately, disallowance under the TDS provision was sustained because audited accounts and auditor silence did not excuse the assessee's statutory failure to deduct tax at source.
Assessment of income on account of unsubstantiated purchases was affirmed where the assessee failed to produce parties, documents or reconcile sundry balances; the tribunal upheld CIT(A)/NFAC direction to adopt a reasonable profit rate (informed by but not applying section 44AD) instead of disallowing all purchases. Separately, disallowance under the TDS provision was sustained because audited accounts and auditor silence did not excuse the assessee's statutory failure to deduct tax at source.
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