Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
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The summary focuses on various issues related to the taxation of banks, covering disallowances u/s 14A, interest deductibility on IPDI bonds, taxation of bad debt recoveries, applicability of MAT provisions u/s 115JB, treatment of broken period interest, amortization of premium on HTM securities, taxation of unrealized interest on NPAs, deduction u/s 36(1)(viii), loss on sale of assets to ARCs, and disallowance of payments made to RBI for non-compliance. The ITAT relied on its own precedents and High Court judgments to provide favorable decisions for the assessee bank on most issues, emphasizing principles like following RBI guidelines, substance over form, and excluding penalties for violating internal regulations from disallowance under Explanation 1 to Section 37.
The summary focuses on various issues related to the taxation of banks, covering disallowances u/s 14A, interest deductibility on IPDI bonds, taxation of bad debt recoveries, applicability of MAT provisions u/s 115JB, treatment of broken period interest, amortization of premium on HTM securities, taxation of unrealized interest on NPAs, deduction u/s 36(1)(viii), loss on sale of assets to ARCs, and disallowance of payments made to RBI for non-compliance. The ITAT relied on its own precedents and High Court judgments to provide favorable decisions for the assessee bank on most issues, emphasizing principles like following RBI guidelines, substance over form, and excluding penalties for violating internal regulations from disallowance under Explanation 1 to Section 37.
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