Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The ITAT, an Appellate Tribunal, addressed the issue of TDS u/s 194A. The case involved delay interest charged by a broker, treated as finance cost, without TDS deduction. ITAT held that interest paid for delayed payments, not on borrowed capital, isn't covered u/s 2(28A). Citing a similar case, ITAT directed AO to delete the addition, allowing the assessee's appeal. The decision clarified that Section 194A applies to interest on borrowed capital, not on delayed purchase payments.
The ITAT, an Appellate Tribunal, addressed the issue of TDS u/s 194A. The case involved delay interest charged by a broker, treated as finance cost, without TDS deduction. ITAT held that interest paid for delayed payments, not on borrowed capital, isn't covered u/s 2(28A). Citing a similar case, ITAT directed AO to delete the addition, allowing the assessee's appeal. The decision clarified that Section 194A applies to interest on borrowed capital, not on delayed purchase payments.
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