Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The assessee claimed deduction for interest and late fees paid on account of delay in filing GST returns. The authorities disallowed the claim, invoking Explanation 1 to Section 37(1) of the Income Tax Act. The Tribunal held that the interest and late fees were compensatory in nature, levied for non-compliance with the GST Act provisions, and not for committing any prohibited offence. Hence, such expenses are allowable as business expenditure u/s 37(1). The Tribunal relied on the precedent of ITO vs. Virtue Financial Services (P) Ltd, which allowed deduction for interest on delayed statutory payments as compensatory expenses. Accordingly, the assessee's grounds were allowed, and interest and late fees on delayed GST returns were held deductible u/s 37(1).
The assessee claimed deduction for interest and late fees paid on account of delay in filing GST returns. The authorities disallowed the claim, invoking Explanation 1 to Section 37(1) of the Income Tax Act. The Tribunal held that the interest and late fees were compensatory in nature, levied for non-compliance with the GST Act provisions, and not for committing any prohibited offence. Hence, such expenses are allowable as business expenditure u/s 37(1). The Tribunal relied on the precedent of ITO vs. Virtue Financial Services (P) Ltd, which allowed deduction for interest on delayed statutory payments as compensatory expenses. Accordingly, the assessee's grounds were allowed, and interest and late fees on delayed GST returns were held deductible u/s 37(1).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
