Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Clause (e) of section 43B, as amended to include interest payable to co-operative banks effective 01-04-2018, does not apply to assessment year 2017-18 unless the assessee qualified as a scheduled bank; a notified scheduled bank was already covered pre-amendment. Because the assessee did not pay interest due to Punjab and Maharashtra Co-operative Bank on or before the due date for filing under section 139(1), the interest is disallowable under section 43B. Capitalization of such interest into work-in-progress does not prevent the disallowance; decision favours revenue.
Clause (e) of section 43B, as amended to include interest payable to co-operative banks effective 01-04-2018, does not apply to assessment year 2017-18 unless the assessee qualified as a scheduled bank; a notified scheduled bank was already covered pre-amendment. Because the assessee did not pay interest due to Punjab and Maharashtra Co-operative Bank on or before the due date for filing under section 139(1), the interest is disallowable under section 43B. Capitalization of such interest into work-in-progress does not prevent the disallowance; decision favours revenue.
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