https://www.taxtmi.com/caselaws?id=790470 Expenditure incurred for conversion charges linked to change of land use on land not owned by the assessee was held not to qualify for depreciation, because it was connected with land-use rights rather than a depreciable asset, and Explanation 1 to section 32 could not be extended to such land-related outlay. The alternative claim for revenue deduction of the conversion charges and related interest also failed, as the expenditure did not satisfy section 36(1)(iii) or section 37(1), and the additional grounds were treated as a later, impermissible change of stand. Penalty under section 271(1)(c) was deleted because the disallowance arose from a debatable claim without proof of concealment or inaccurate particulars. en-us Mon, 20 Apr 2026 00:00:00 +0530 Thu, 23 Apr 2026 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790470 Expenditure incurred for conversion charges linked to change of land use on land not owned by the assessee was held not to qualify for depreciation, because it was connected with land-use rights rather than a depreciable asset, and Explanation 1 to section 32 could not be extended to such land-related outlay. The alternative claim for revenue deduction of the conversion charges and related interest also failed, as the expenditure did not satisfy section 36(1)(iii) or section 37(1), and the additional grounds were treated as a later, impermissible change of stand. Penalty under section 271(1)(c) was deleted because the disallowance arose from a debatable claim without proof of concealment or inaccurate particulars. Case-Laws Income Tax Mon, 20 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790470