Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
The ITAT held that an outstanding balance taken over under a Business Transfer Agreement in a slump sale could not be treated as an interest-free advance to a group company for making a deemed interest addition. It accepted that the amount was not an actual loan from borrowed funds but part of a commercially expedient business arrangement, and also relied on the Revenue's consistent acceptance of the same position in later years. The Tribunal further found that a larger notional disallowance was untenable where the actual interest debited in the year was minimal. The impugned addition was deleted and income was directed to be recomputed accordingly.
The ITAT held that an outstanding balance taken over under a Business Transfer Agreement in a slump sale could not be treated as an interest-free advance to a group company for making a deemed interest addition. It accepted that the amount was not an actual loan from borrowed funds but part of a commercially expedient business arrangement, and also relied on the Revenue's consistent acceptance of the same position in later years. The Tribunal further found that a larger notional disallowance was untenable where the actual interest debited in the year was minimal. The impugned addition was deleted and income was directed to be recomputed accordingly.
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