Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Interest arising on internal placements between an Indian branch and its head office or overseas branches was treated as a payment to self and not taxable income; interest from other overseas banks also escaped tax because the statutory condition for source-based taxation was not met, and the specific interest provision excluded resort to the general charging provision. Disallowances under section 14A failed where concessional-rate interest remained taxable, and also where interest-free funds covered exempt-income investments. Broken period interest on securities held as stock-in-trade, year-end foreign exchange revaluation loss, club membership fee for employees, and CRR/SLR shortfall payment were all held allowable. Interest charged on refund processing was not sustained, and bad debt write-back was remitted only for verification of prior taxation.
Interest arising on internal placements between an Indian branch and its head office or overseas branches was treated as a payment to self and not taxable income; interest from other overseas banks also escaped tax because the statutory condition for source-based taxation was not met, and the specific interest provision excluded resort to the general charging provision. Disallowances under section 14A failed where concessional-rate interest remained taxable, and also where interest-free funds covered exempt-income investments. Broken period interest on securities held as stock-in-trade, year-end foreign exchange revaluation loss, club membership fee for employees, and CRR/SLR shortfall payment were all held allowable. Interest charged on refund processing was not sustained, and bad debt write-back was remitted only for verification of prior taxation.
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