Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
ITAT held that actual contractual rent under registered leave-and-license arrangements, together with separately agreed commercial amenity charges, could not be replaced by an enhanced annual letting value absent cogent material of suppressed rent, sham transactions, or unaccounted consideration; the addition under section 23(1)(a) was deleted. It also held that interest on borrowed capital used to acquire let-out commercial property was deductible under section 24(b) because the borrowings had a direct nexus with acquisition and the Revenue could not deny relief while taxing the property under the head income from house property; the disallowance was deleted. In the absence of exempt income, section 14A and Rule 8D could not be invoked, and the Finance Act 2022 Explanation was treated as prospective.
ITAT held that actual contractual rent under registered leave-and-license arrangements, together with separately agreed commercial amenity charges, could not be replaced by an enhanced annual letting value absent cogent material of suppressed rent, sham transactions, or unaccounted consideration; the addition under section 23(1)(a) was deleted. It also held that interest on borrowed capital used to acquire let-out commercial property was deductible under section 24(b) because the borrowings had a direct nexus with acquisition and the Revenue could not deny relief while taxing the property under the head income from house property; the disallowance was deleted. In the absence of exempt income, section 14A and Rule 8D could not be invoked, and the Finance Act 2022 Explanation was treated as prospective.
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