Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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.
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