Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
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...
A partnership firm is a separate taxable entity under the Income-tax Act only from the date it comes into existence, so it cannot claim interest expenditure attributable to an earlier period when the business was still a proprietorship concern. The Tribunal held that the firm, having commenced on 15.06.2014, was entitled to deduct expenses only for its own period of existence and not for 01.04.2014 to 14.06.2014. The proportionate disallowance of interest made by the Assessing Officer and upheld in first appeal was therefore sustained. The delay in filing the appeal was condoned on sufficient cause.
A partnership firm is a separate taxable entity under the Income-tax Act only from the date it comes into existence, so it cannot claim interest expenditure attributable to an earlier period when the business was still a proprietorship concern. The Tribunal held that the firm, having commenced on 15.06.2014, was entitled to deduct expenses only for its own period of existence and not for 01.04.2014 to 14.06.2014. The proportionate disallowance of interest made by the Assessing Officer and upheld in first appeal was therefore sustained. The delay in filing the appeal was condoned on sufficient cause.
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