Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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.