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...
The Tribunal held that, after substitution of section 80AC from 01.04.2018, deductions under Part C of Chapter VIA, including section 80P, are admissible only if the return is furnished within the due date under section 139(1). It accepted that this amendment applies from AY 2018-19 and followed the Madras High Court ruling in Veerappampalayam Primary Agricultural Cooperative Credit Society Ltd. A claim made only in a return filed in response to section 148, where no return had been filed within the section 139 due date, could not cure the default. The denial of deduction under section 80P was therefore sustained and the appeal dismissed.
The Tribunal held that, after substitution of section 80AC from 01.04.2018, deductions under Part C of Chapter VIA, including section 80P, are admissible only if the return is furnished within the due date under section 139(1). It accepted that this amendment applies from AY 2018-19 and followed the Madras High Court ruling in Veerappampalayam Primary Agricultural Cooperative Credit Society Ltd. A claim made only in a return filed in response to section 148, where no return had been filed within the section 139 due date, could not cure the default. The denial of deduction under section 80P was therefore sustained and the appeal dismissed.
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