Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
Business set-up is distinct from commercial commencement: once a division is established and ready to perform its functions, expenditure cannot be denied solely because commercial operations have not begun. Contemporaneous evidence recording completion of the first phase and commencement of production supports the division's operational status; subsequent financial distress or action against assets cannot retrospectively alter that status. Appellate authorities must consider written submissions and material evidence, including annual reports, and provide reasoned findings rather than merely adopting assessment reasoning. Expenditure of a newly established division cannot be categorised wholesale as capital; deductibility of each item remains subject to applicable statutory conditions.
Business set-up is distinct from commercial commencement: once a division is established and ready to perform its functions, expenditure cannot be denied solely because commercial operations have not begun. Contemporaneous evidence recording completion of the first phase and commencement of production supports the division's operational status; subsequent financial distress or action against assets cannot retrospectively alter that status. Appellate authorities must consider written submissions and material evidence, including annual reports, and provide reasoned findings rather than merely adopting assessment reasoning. Expenditure of a newly established division cannot be categorised wholesale as capital; deductibility of each item remains subject to applicable statutory conditions.
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