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...
On fresh examination of the capital bond agreement, the ITAT found that clause 5 created a binding obligation on the assessee to pay accrued interest to Prestige. Because the bond funds were provided by Prestige and the related interest income had been assessed in the assessee's hands, the corresponding interest liability was deductible as an allowable expenditure. The earlier view that no enforceable obligation existed was rejected, and the disallowance of interest paid to Prestige was directed to be deleted. The appeals were allowed to that extent.
On fresh examination of the capital bond agreement, the ITAT found that clause 5 created a binding obligation on the assessee to pay accrued interest to Prestige. Because the bond funds were provided by Prestige and the related interest income had been assessed in the assessee's hands, the corresponding interest liability was deductible as an allowable expenditure. The earlier view that no enforceable obligation existed was rejected, and the disallowance of interest paid to Prestige was directed to be deleted. The appeals were allowed to that extent.
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