AO Cannot Blow Hot & Cold—TDR Allowed; Penalty Deleted; Interest Disallowance Gone

Essae Suhagraja Private Limited Vs DCIT (ITAT Bangalore) AO Cannot Blow Hot & Cold—TDR Allowed; Penalty Deleted; Interest Disallowance Gone- Contradictory Stand by AO on TDR Cost—ITAT Directs Allowance; Penalty u/s 270A Deleted; Interest Disallowance u/s 36(1)(iii) Also Reversed AY 2018-19 – TDR Cost of ₹5.45 Cr Assessee claimed cost of Transferable Development Rights (TDR) as business expenditure. AO disallowed it in reassessment holding: No sale of flats in FY 2017-18 → TDR must be capitalised into WIP Deduction allowable only when flats are sold However, in AY 2020-21 asses...