Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
The ITAT allowed the assessee's appeal. Regarding the transfer pricing adjustment for interest charged on loans, the ITAT upheld the CIT(A)'s deletion of the adjustment, relying on the Cotton Natural (I) Pvt. Ltd. case, which applied the LIBOR rate for foreign currency denominated loans. The ITAT also upheld the CIT(A)'s deletion of the adjustment for commission on providing a corporate guarantee, following the Vaibhav Global Limited case and the Supreme Court's decision in S.A. Builders Ltd. The ITAT agreed with the assessee's contention on Section 14A disallowance, as sufficient own funds were available for investments, based on the Supreme Court's ruling in South Indian Bank Ltd. The ITAT upheld the deletion of the addition u/s 40(a) for delayed TDS deposit, relying on the Calcutta Export Company case.
The ITAT allowed the assessee's appeal. Regarding the transfer pricing adjustment for interest charged on loans, the ITAT upheld the CIT(A)'s deletion of the adjustment, relying on the Cotton Natural (I) Pvt. Ltd. case, which applied the LIBOR rate for foreign currency denominated loans. The ITAT also upheld the CIT(A)'s deletion of the adjustment for commission on providing a corporate guarantee, following the Vaibhav Global Limited case and the Supreme Court's decision in S.A. Builders Ltd. The ITAT agreed with the assessee's contention on Section 14A disallowance, as sufficient own funds were available for investments, based on the Supreme Court's ruling in South Indian Bank Ltd. The ITAT upheld the deletion of the addition u/s 40(a) for delayed TDS deposit, relying on the Calcutta Export Company case.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
