S. 36(1)(iii) : Interest on borrowed capital – Interest bearing funds were applied for making investment in equity shares and alleged investment was for non-business purposes-Disallowance of interest is held to be justified. [S. 14A, R. 8D]

S. 23 : Income from house property–Annual value-Municipal rateable value – Municipal rateable value is a recognised basis for determination of ALV, the AO cannot disregard the municipal rateable value and substitute some expected rent to be received. [S. 22]

S. 23 : Income from house property – Annual value – Vacancy allowance -Due to fall in property prices failed to let out same year after year because of which property remained vacant-Entitle to vacancy allowance. [S. 22, 23(1)(c)]

S. 170 : Succession to business otherwise than on death -Capital gains- Conversion of private Limited company to LLP- de hors applicability of section 47A(4), would be subject to liability of assessee LLP as a successor entity. [ S. 5,45 , 47A(4)]

S. 80IA :Industrial undertakings – Audit report- Filing of an audit report is procedural and directory in nature- It can also be filed before Appellate Authority .[Form No 10CCB ]

S. 72A : Carry forward and set off of accumulated loss – Conversion of Private Limited Company to LLP – Failure to satisfy conditions laid down in proviso – Carry forward of losses of erstwhile company by LLP is not entitled .[ S.47 xiiib), 72A (6A), Limited Liability Partnership Act , 2008 , S. 56,58 (4)]

S. 49 : Capital gains – Previous owner – Cost of acquisition – Conversion of Private Limited Company to LLP -Capital assets become property of assessee by succession, inheritance or devolution, cost of acquisition of assets shall be deemed to be cost for which previous owner of property had acquired same. [ S. 2(42A)45 , 49(1)(iii)]

S. 48 : Capital gains – Computation – Full value of consideration – Conversion of a private limited company into assessee-LLP -Book value – Book value was to be regarded as full value of consideration for purpose of computation of capital gains .[ S.45 , 47 ]

S. 47A : Capital gains – Withdrawal of exemption – Conversion of firm in to LLP – Provision will apply only for purpose of withdrawing an exemption earlier availed by an assessee and not for determination of exemption under section 47(xiiib) of the Act .[ S. 45 47A(4)]

S.47(xiiib): Capital gains – Transaction not regarded as transfer – Conversion of firm in to LLP– Transfer -On cumulative satisfaction of conditions (a) to (f) of proviso to section 47(xiiib) would not be chargeable to capital gains [ S.45 ]