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...
The ITAT held that penalty for TDS default under section 272A(2)(g) was not justified because the assessee had shown reasonable cause, bringing the case within the protection of section 273B. Although the defaults related to different periods and the appeal was not a duplicate, the merits were covered by an earlier order in the assessee's own case on similar facts for the same assessment year. Following that precedent, the Tribunal upheld deletion of the penalty and dismissed the Revenue's appeal.
The ITAT held that penalty for TDS default under section 272A(2)(g) was not justified because the assessee had shown reasonable cause, bringing the case within the protection of section 273B. Although the defaults related to different periods and the appeal was not a duplicate, the merits were covered by an earlier order in the assessee's own case on similar facts for the same assessment year. Following that precedent, the Tribunal upheld deletion of the penalty and dismissed the Revenue's appeal.
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