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    <title>2024 (7) TMI 1529 - DELHI HIGH COURT</title>
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    <description>Transactions under a sanctioned scheme were held to fall in an earlier assessment year because the appointed date ended on 31 March 2011, so additions under sections 28(iv) and 56(2)(viia) did not survive; the increase in general reserves was not treated as a business benefit or perquisite, and the amendment to section 47(vii) was treated as curative and retrospective. Disallowances under section 14A, section 36(1)(iii), section 40A(3), transfer pricing and related expense claims were deleted where no exempt income arose, investments were commercially expedient, and borrowed funds supported the assessee&#039;s business. Interest for delayed payment of indirect taxes was treated as compensatory, not penal, so disallowance failed. No substantial question of law arose.</description>
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      <link>https://www.taxtmi.com/caselaws?id=457873</link>
      <description>Transactions under a sanctioned scheme were held to fall in an earlier assessment year because the appointed date ended on 31 March 2011, so additions under sections 28(iv) and 56(2)(viia) did not survive; the increase in general reserves was not treated as a business benefit or perquisite, and the amendment to section 47(vii) was treated as curative and retrospective. Disallowances under section 14A, section 36(1)(iii), section 40A(3), transfer pricing and related expense claims were deleted where no exempt income arose, investments were commercially expedient, and borrowed funds supported the assessee&#039;s business. Interest for delayed payment of indirect taxes was treated as compensatory, not penal, so disallowance failed. No substantial question of law arose.</description>
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