Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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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