Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
The ITAT held that: The assessee was entitled to claim deduction for interest expenses incurred in relation to interest-free loans granted to wholly owned subsidiaries operating in the same line of business, as the loans were for commercial expediency. The cash deposits were made in the normal course of the assessee's restaurant/hospitality business, and the addition u/s 68 was deleted. Regarding rental income receipts, the issue was set aside for denovo adjudication by the AO after necessary inquiries/verification, as the room and food/banquet income was included under "Revenue from Operations" in the P&L account, and details of TDS and rent earned were not disputed.
The ITAT held that: The assessee was entitled to claim deduction for interest expenses incurred in relation to interest-free loans granted to wholly owned subsidiaries operating in the same line of business, as the loans were for commercial expediency. The cash deposits were made in the normal course of the assessee's restaurant/hospitality business, and the addition u/s 68 was deleted. Regarding rental income receipts, the issue was set aside for denovo adjudication by the AO after necessary inquiries/verification, as the room and food/banquet income was included under "Revenue from Operations" in the P&L account, and details of TDS and rent earned were not disputed.
Note: It is a system-generated summary and is for quick reference only.