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...
Assessee sought deduction under section 80JJAA but failed to claim it in the original return and did not file Form 10DA within the prescribed time; the tribunal applied the statutory rule that deductions under Chapter VIA require a claim in the return and concluded that section 80A(5) precludes allowance of deductions not claimed in the return. Because the claim was first made before the CIT(A) and not in the return, the deduction under section 80JJAA was disallowed.
Assessee sought deduction under section 80JJAA but failed to claim it in the original return and did not file Form 10DA within the prescribed time; the tribunal applied the statutory rule that deductions under Chapter VIA require a claim in the return and concluded that section 80A(5) precludes allowance of deductions not claimed in the return. Because the claim was first made before the CIT(A) and not in the return, the deduction under section 80JJAA was disallowed.
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