Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Interest earned on fixed deposits compulsorily created under subsidy sanction conditions for a cold chain facility was held to have a direct nexus with the business activity, not to be income from other sources. On that basis, the Tribunal treated the interest as business income and held it eligible for deduction under section 80IB(11), deleting the disallowance. It also found the additions for savings bank interest and income-tax refund interest factually unsustainable, as no savings account existed in the assessee's name and no deduction had been claimed for refund interest. Those additions were deleted, and the appeal was allowed.
Interest earned on fixed deposits compulsorily created under subsidy sanction conditions for a cold chain facility was held to have a direct nexus with the business activity, not to be income from other sources. On that basis, the Tribunal treated the interest as business income and held it eligible for deduction under section 80IB(11), deleting the disallowance. It also found the additions for savings bank interest and income-tax refund interest factually unsustainable, as no savings account existed in the assessee's name and no deduction had been claimed for refund interest. Those additions were deleted, and the appeal was allowed.
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