Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
Depreciation was denied on conversion charges paid for change of land use because the expenditure related to land owned by another entity and did not create any independent depreciable asset in the assessee's hands; Explanation 1 to section 32 was held confined to capital expenditure on a building or work connected with a building, not land or rights in land. The alternative claim for revenue deduction and the related interest claim also failed because the assessee did not own the underlying asset and the business-purpose nexus required for section 36(1)(iii) was not established. Penalty was deleted under section 271(1)(c) since the claim was fully disclosed and debatable, with no concealment or inaccurate particulars.
Depreciation was denied on conversion charges paid for change of land use because the expenditure related to land owned by another entity and did not create any independent depreciable asset in the assessee's hands; Explanation 1 to section 32 was held confined to capital expenditure on a building or work connected with a building, not land or rights in land. The alternative claim for revenue deduction and the related interest claim also failed because the assessee did not own the underlying asset and the business-purpose nexus required for section 36(1)(iii) was not established. Penalty was deleted under section 271(1)(c) since the claim was fully disclosed and debatable, with no concealment or inaccurate particulars.
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