Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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).
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