Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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Claim of Loss - Deduction u/s. 57 - Taxability of real income / net interest income - The Tribunal observed that the investment in perpetual debt instruments (PDIs) was financed by secured debentures. It was established that the funds raised through debentures were not meant for investment in PDIs but for the objectives of the company. The Tribunal allowed the deduction of interest expenditure against interest income, considering only the net income liable for taxation. - ITAT emphasized that only real income, subject to the provisions of the Act, is taxable.
Claim of Loss - Deduction u/s. 57 - Taxability of real income / net interest income - The Tribunal observed that the investment in perpetual debt instruments (PDIs) was financed by secured debentures. It was established that the funds raised through debentures were not meant for investment in PDIs but for the objectives of the company. The Tribunal allowed the deduction of interest expenditure against interest income, considering only the net income liable for taxation. - ITAT emphasized that only real income, subject to the provisions of the Act, is taxable.
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