Held that the assessee never claimed deduction towards interest of Rs. 6 crore in past, but capitalized it to value of investment initially acquired at Rs. 50 crores. Amount of interest capitalized along with purchase cost, was also liable to be deducted from full value of consideration for computing amount of LTCG on sale of debentures. Revision is not justified. As regards allowability of remuneration paid to partners , since two views were possible on this point and Assessing Officer had taken one of them which was in favour of assessee, impugned revision is unjustified. (AY. 2016-17)
Bharatnagar Buildcon LLP. v. PCIT (2023) 203 ITD 539 (Pune) (Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital gains-Interest paid capitalised-Purchase cost-Sale of debentures-Interest salary, etc. paid by firm-Two views possible-Revision order is quashed. [S. 40(b), 45, 55]