Income Tax - Highlights / Catch Notes
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Disallowance of prior period expenses pertaining to expenditure ...
Expenses, depreciation, revenue recognition, grants, fees, disallowances - a legal tussle.
Case Laws Income Tax
November 8, 2024
Disallowance of prior period expenses pertaining to expenditure crystallized or details received after completion of earlier years' audits. Genuineness not doubted, remitted to AO for verification of non-claim in prior years. Addition of depreciation on estimated 10% cost towards stamp duty/registration charges on properties with pending lease/sub-lease execution remitted to AO for de novo verification as per jurisdictional High Court order. Revenue de-recognition issue remanded to AO based on Supreme Court decision and application u/s 158A(1). Administrative charges on Andrews Ganj Project disallowed based on High Court ruling of no accrual of income. Grants-in-aid expenditure allowed as wholly and exclusively for business. Revenue recognition of loan fees on realization basis upheld based on certainty of realization, C&AG directives, and High Court decision. Disallowance u/s 14A rejected as no exempt income claimed. Correct TDS credit remitted to AO for factual verification. Financial charges written off allowed as deduction based on High Court decision. Prior period expenses disallowed due to lack of evidence of crystallization. Disallowance u/s 14A limited to 1% of dividend income pre-Rule 8D. CSR expenses pre-April 1, 2015 allowed based on High Court ruling. Prior period expenditure.
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