Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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