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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
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Section 43B of the Income Tax Act disallows certain deductions for unpaid statutory dues like interest, tax, duty, etc. The key points are: Unpaid interest on loans from World Bank or State Government is not covered u/s 43B clauses (d), (da), or (e) as these clauses are specific to interest payable to financial institutions, NBFCs, and banks. Explanation 4 to Section 43B clarifies the institutions covered, excluding World Bank and State Government. Therefore, disallowance of unpaid interest on World Bank loan is not justified u/s 43B. Regarding electricity duty collected from consumers, it is not a tax or duty levied on the assessee but part of the commercial transaction of electricity supply. Section 43B is not applicable as the duty is not imposed on the assessee but collected from consumers and remitted to the government. The assessee's appeal is allowed, following the Kerala High Court ruling that Section 43B deals with amounts payable to the sovereign qua sovereign, not qua principal.
Section 43B of the Income Tax Act disallows certain deductions for unpaid statutory dues like interest, tax, duty, etc. The key points are: Unpaid interest on loans from World Bank or State Government is not covered u/s 43B clauses (d), (da), or (e) as these clauses are specific to interest payable to financial institutions, NBFCs, and banks. Explanation 4 to Section 43B clarifies the institutions covered, excluding World Bank and State Government. Therefore, disallowance of unpaid interest on World Bank loan is not justified u/s 43B. Regarding electricity duty collected from consumers, it is not a tax or duty levied on the assessee but part of the commercial transaction of electricity supply. Section 43B is not applicable as the duty is not imposed on the assessee but collected from consumers and remitted to the government. The assessee's appeal is allowed, following the Kerala High Court ruling that Section 43B deals with amounts payable to the sovereign qua sovereign, not qua principal.
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