Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Corporate guarantee commission under the interest saving method required allocation of the benefit between guarantor and borrower; in the absence of fuller facts, the Tribunal directed a 50:50 split and clarified that this is fact-specific, not a universal rule. Book profit computation could not be increased by the Section 14A disallowance in the manner adopted by the Assessing Officer; following Vireet Investment, the figure had to be recomputed under clause (f) of Explanation 1 without applying Rule 8D. For the set-aside years, the Assessing Officer was also directed to verify the assessment records, consider the assessee's submissions, and recompute total income after giving effect to earlier reliefs.
Corporate guarantee commission under the interest saving method required allocation of the benefit between guarantor and borrower; in the absence of fuller facts, the Tribunal directed a 50:50 split and clarified that this is fact-specific, not a universal rule. Book profit computation could not be increased by the Section 14A disallowance in the manner adopted by the Assessing Officer; following Vireet Investment, the figure had to be recomputed under clause (f) of Explanation 1 without applying Rule 8D. For the set-aside years, the Assessing Officer was also directed to verify the assessment records, consider the assessee's submissions, and recompute total income after giving effect to earlier reliefs.
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