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 �

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