Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
Short deduction of tax at source did not warrant disallowance under section 40(a)(ia), and the related royalty-characterisation questions were treated as academic. Corporate guarantee commission was upheld at 0.5% because a corporate guarantee to an associated enterprise is not comparable to a bank guarantee, so no substantial question of law arose. On section 14A, where the assessee's own and other non-interest-bearing funds exceeded tax-free investments, a presumption arose that the investments came from interest-free funds, defeating interest disallowance under Rule 8D(2)(ii). Only the re-framed question under section 14A read with Rule 8D(2)(iii) concerning investments yielding exempt income during the year was entertained.
Short deduction of tax at source did not warrant disallowance under section 40(a)(ia), and the related royalty-characterisation questions were treated as academic. Corporate guarantee commission was upheld at 0.5% because a corporate guarantee to an associated enterprise is not comparable to a bank guarantee, so no substantial question of law arose. On section 14A, where the assessee's own and other non-interest-bearing funds exceeded tax-free investments, a presumption arose that the investments came from interest-free funds, defeating interest disallowance under Rule 8D(2)(ii). Only the re-framed question under section 14A read with Rule 8D(2)(iii) concerning investments yielding exempt income during the year was entertained.
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