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of <h1>SC upholds denial of deduction under Rule 6EB for interest on NPAs, rejects review petitions</h1> <h3>HOUSING AND URBAN DEVELOPMENT CORPORATION LIMITED Versus ADDITIONAL COMMISSIONER OF INCOME TAX </h3> The SC dismissed the review petitions filed by the petitioner challenging the prior order that denied entitlement to deduction under Rule 6EB for interest ... Review petition - Claim for deduction on account of the method for determining an NPA - entitlement to deduction on account of de-recognition of interest accruing upon NPAs applying Rule 6EB of the Income Tax Rules, 1962 As decided by SC [2024 (11) TMI 1394 - SC ORDER] purpose of classification of debts as NPA by the NHB and the purpose for non-recognition of income for the purposes of the Act are different. Given the wording of the relevant provisions of the Act and the NHB Act, it is not possible to agree to HUDCO's proposition that with every change in the NHB guidelines there would be a corresponding automatic change in Rule 6EB. Even otherwise, as pointed out by the ITAT, the real income principle would have no application as far as Section 43D of the Act HELD THAT:- Application seeking exemption from filing certified copy of the impugned orders is allowed. Application seeking oral hearing of the Review Petitions is rejected. These review petitions have been filed by the petitioner - Housing & Urban Development Corporation Limited seeking review of the Order [2024 (11) TMI 1394 - SC ORDER] passed in the captioned Special Leave Petitions whereby the said petitions were dismissed. As carefully gone through the said Order and the record. In our opinion, no case for review is made out. The Supreme Court of India, through Justices J.B. Pardiwala and R. Mahadeva, issued an order allowing exemption from filing certified copies of the impugned orders but rejecting the application for oral hearing of the review petitions. The petitioner, Housing & Urban Development Corporation Limited, sought review of the Order dated 27th November 2024, which dismissed the Special Leave Petitions. Upon examination, the Court held that 'no case for review is made out' and accordingly dismissed the review petitions on merits.
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