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    <title>2025 (2) TMI 188 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=765642</link>
    <description>ITAT Delhi held that capital subsidy treatment should await SC decision due to pending litigation and lack of reasonable certainty for revenue recognition per Chainrup Sampatram. After-sales expense provision was allowed following Bharat Earth Movers precedent. Section 14A disallowance was restricted to 5% of exempt income. Section 80G deduction and dividend exemption u/s 10(34) were allowed in principle subject to AO verification. Prior period expenditure was permitted based on consistency principle and revenue neutrality. Assessment u/s 153A was quashed as no additions were made from seized material per Abhisar Buildwell. Unexplained expenditure addition based on loose papers from uncontrolled premises was deleted citing Girish Choudhry. Excess bagasse stock qualified for section 80IA deduction as business income.</description>
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    <pubDate>Wed, 29 Jan 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=765642</link>
      <description>ITAT Delhi held that capital subsidy treatment should await SC decision due to pending litigation and lack of reasonable certainty for revenue recognition per Chainrup Sampatram. After-sales expense provision was allowed following Bharat Earth Movers precedent. Section 14A disallowance was restricted to 5% of exempt income. Section 80G deduction and dividend exemption u/s 10(34) were allowed in principle subject to AO verification. Prior period expenditure was permitted based on consistency principle and revenue neutrality. Assessment u/s 153A was quashed as no additions were made from seized material per Abhisar Buildwell. Unexplained expenditure addition based on loose papers from uncontrolled premises was deleted citing Girish Choudhry. Excess bagasse stock qualified for section 80IA deduction as business income.</description>
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      <pubDate>Wed, 29 Jan 2025 00:00:00 +0530</pubDate>
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