Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Disciplinary proportionality requires penalties for Authorised Representative misconduct to match proven harm, leading to reconsideration of registrat...
Income tax treatment of membership fees received in advance: The membership fees comprise a non-refundable portion and an advance amount for availing discounted services. The non-refundable portion is taxable upfront, while the advance amount is taxable on a deferred basis over the service period, unless there is evidence of a different revenue recognition pattern. The assessee's methodology of offering the entire amount to tax has been accepted by the Revenue authorities in previous years. Disallowance u/s 14A: No disallowance is required u/s 14A in the absence of any exempt income earned by the assessee. Interest paid on plot installments: The interest expenditure incurred on acquisition of a capital asset is not allowable as a deduction under the proviso to Section 36(1)(iii). The interest cost should be added to the cost of the land acquired. Ad-hoc disallowance of expenses: No ad-hoc disallowance of expenses, such as 5% of business promotion, traveling, and telephone expenses, is permissible without providing a rationale for such disallowance. TDS on credit card transaction charges: As per Notification No. 56/2012 and the Delhi High Court's decision in JDS Apparels Pvt. Ltd., no TDS is required to be deducted u/s 194H on transaction charges levied by banks on credit card payments received from customers.
Income tax treatment of membership fees received in advance: The membership fees comprise a non-refundable portion and an advance amount for availing discounted services. The non-refundable portion is taxable upfront, while the advance amount is taxable on a deferred basis over the service period, unless there is evidence of a different revenue recognition pattern. The assessee's methodology of offering the entire amount to tax has been accepted by the Revenue authorities in previous years. Disallowance u/s 14A: No disallowance is required u/s 14A in the absence of any exempt income earned by the assessee. Interest paid on plot installments: The interest expenditure incurred on acquisition of a capital asset is not allowable as a deduction under the proviso to Section 36(1)(iii). The interest cost should be added to the cost of the land acquired. Ad-hoc disallowance of expenses: No ad-hoc disallowance of expenses, such as 5% of business promotion, traveling, and telephone expenses, is permissible without providing a rationale for such disallowance. TDS on credit card transaction charges: As per Notification No. 56/2012 and the Delhi High Court's decision in JDS Apparels Pvt. Ltd., no TDS is required to be deducted u/s 194H on transaction charges levied by banks on credit card payments received from customers.
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