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...
Section 68 was largely satisfied where the assessee produced the lender's registration, PAN, bank statements, debenture documents, confirmation and source-of-source material; nil income alone did not negate creditworthiness, so only limited third-party verification under section 133(6) was left open if the Assessing Officer still needed the lender's accounts. Interest disallowance under section 40A(2)(b) failed because the lender was only a creditor, not shown to be a covered related concern, and no basis existed for adopting 6% as a reasonable rate. Proportionate interest disallowance under section 36(1)(iii) was deleted since the borrowing was for working capital, not capital asset acquisition. A flat 10% ad hoc expense disallowance was set aside for fresh verification. CSR disallowance was upheld, and TDS credit was directed to be verified.
Section 68 was largely satisfied where the assessee produced the lender's registration, PAN, bank statements, debenture documents, confirmation and source-of-source material; nil income alone did not negate creditworthiness, so only limited third-party verification under section 133(6) was left open if the Assessing Officer still needed the lender's accounts. Interest disallowance under section 40A(2)(b) failed because the lender was only a creditor, not shown to be a covered related concern, and no basis existed for adopting 6% as a reasonable rate. Proportionate interest disallowance under section 36(1)(iii) was deleted since the borrowing was for working capital, not capital asset acquisition. A flat 10% ad hoc expense disallowance was set aside for fresh verification. CSR disallowance was upheld, and TDS credit was directed to be verified.
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