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Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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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