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 56(2)(x) applies to any immovable property, so agricultural land purchased by the assessee was not from its scope merely because it was not a capital asset. The Tribunal held that the capital-asset character of agricultural land is relevant for the seller's capital gains computation, not for the buyer's liability under this provision, and therefore the addition was justified. It also found that the assessee had sought adoption of the DVO valuation instead of the higher stamp duty value and could not later challenge that very report or demand a fresh valuation exercise. The appeal was dismissed and the addition sustained.
Section 56(2)(x) applies to any immovable property, so agricultural land purchased by the assessee was not from its scope merely because it was not a capital asset. The Tribunal held that the capital-asset character of agricultural land is relevant for the seller's capital gains computation, not for the buyer's liability under this provision, and therefore the addition was justified. It also found that the assessee had sought adoption of the DVO valuation instead of the higher stamp duty value and could not later challenge that very report or demand a fresh valuation exercise. The appeal was dismissed and the addition sustained.
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