https://www.taxtmi.com/caselaws?id=792574 Appellate powers may admit a new legal ground where facts are on record and the issue is necessary to determine tax liability; the restriction on revised claims before the Assessing Officer does not limit appellate authorities. Goodwill first arising on amalgamation and non-compete rights qualify as depreciable intangible commercial rights. Interest disallowance on advances to subsidiaries is unwarranted where sufficient interest-free funds exist, no nexus with borrowings is shown, and commercial expediency supports the advances. Disallowance of expenditure on an ad hoc basis requires concrete adverse findings. Connectivity charges require agreement-wise amortisation, while network acquisition requires segregation of tangible and intangible components. Exempt-income disallowance is limited by own funds, exempt-income investments, and exempt income earned. en-us Tue, 26 May 2026 00:00:00 +0530 Sat, 30 May 2026 08:29:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792574 Appellate powers may admit a new legal ground where facts are on record and the issue is necessary to determine tax liability; the restriction on revised claims before the Assessing Officer does not limit appellate authorities. Goodwill first arising on amalgamation and non-compete rights qualify as depreciable intangible commercial rights. Interest disallowance on advances to subsidiaries is unwarranted where sufficient interest-free funds exist, no nexus with borrowings is shown, and commercial expediency supports the advances. Disallowance of expenditure on an ad hoc basis requires concrete adverse findings. Connectivity charges require agreement-wise amortisation, while network acquisition requires segregation of tangible and intangible components. Exempt-income disallowance is limited by own funds, exempt-income investments, and exempt income earned. Case-Laws Income Tax Tue, 26 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792574