Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Interest on fixed deposits subject to prohibitory orders and pending criminal proceedings was held not taxable on accrual because, under the real income principle and the governing circular, income arises only when receipt is sufficiently certain. The fact that the assessee had earlier offered the interest on accrual basis, or that TDS may have been deducted, did not make the uncredited interest taxable while entitlement to the deposits remained uncertain. The court added that if the assessee is ultimately held entitled to the deposits, appropriate additions may then be made. The Tribunal's deletion of the accrued-interest addition was upheld.
Interest on fixed deposits subject to prohibitory orders and pending criminal proceedings was held not taxable on accrual because, under the real income principle and the governing circular, income arises only when receipt is sufficiently certain. The fact that the assessee had earlier offered the interest on accrual basis, or that TDS may have been deducted, did not make the uncredited interest taxable while entitlement to the deposits remained uncertain. The court added that if the assessee is ultimately held entitled to the deposits, appropriate additions may then be made. The Tribunal's deletion of the accrued-interest addition was upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
