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    <title>2023 (3) TMI 1192 - ITAT DELHI</title>
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    <description>Business loss was allowable because the assessee had already set up its real estate business through project arrangements, staffing, and administrative expenditure, even though no revenue had been earned in the year; income in the same year was not a precondition for deductibility. Disallowance under section 40(a)(ia) also failed because the external development charges were capitalised as part of asset cost and were not debited to the profit and loss account, so the provision could not be applied to a non-claimed revenue expense. The assessee obtained relief on both issues.</description>
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      <link>https://www.taxtmi.com/caselaws?id=435806</link>
      <description>Business loss was allowable because the assessee had already set up its real estate business through project arrangements, staffing, and administrative expenditure, even though no revenue had been earned in the year; income in the same year was not a precondition for deductibility. Disallowance under section 40(a)(ia) also failed because the external development charges were capitalised as part of asset cost and were not debited to the profit and loss account, so the provision could not be applied to a non-claimed revenue expense. The assessee obtained relief on both issues.</description>
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      <pubDate>Fri, 24 Mar 2023 00:00:00 +0530</pubDate>
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