Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Bank-specific tax claims were largely upheld: deduction for provision for bad and doubtful debts under section 36(1)(viia), tax treatment of unrealised foreign exchange forward contract gains, CSR expenditure, depreciation on ATMs as computers, depreciation on bank investment portfolio and leased assets, deduction for special reserve, accrual of interest on securities, and the inapplicability of minimum alternate tax to banking companies. On exempt income, the Tribunal accepted verification of own funds and recomputation of administrative disallowance for bank investments. Following binding precedent and no material factual change, the Revenue's appeal was dismissed and the appellate order was sustained on all contested issues.
Bank-specific tax claims were largely upheld: deduction for provision for bad and doubtful debts under section 36(1)(viia), tax treatment of unrealised foreign exchange forward contract gains, CSR expenditure, depreciation on ATMs as computers, depreciation on bank investment portfolio and leased assets, deduction for special reserve, accrual of interest on securities, and the inapplicability of minimum alternate tax to banking companies. On exempt income, the Tribunal accepted verification of own funds and recomputation of administrative disallowance for bank investments. Following binding precedent and no material factual change, the Revenue's appeal was dismissed and the appellate order was sustained on all contested issues.
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