Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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ITAT ruled favorably on multiple issues for the banking assessee. The tribunal allowed deduction under s.36(1)(viia) for NPA provisions, holding them equivalent to provisions for bad and doubtful debts. For s.14A disallowance, matter was remanded to examine administrative expenses allocation despite interest-free funds exceeding investments. Deduction under s.36(1)(vii) was permitted following prior precedent. RBI penalty payment was deemed allowable under s.37 as not being for legal infraction. Interest on Innovative Perpetual Debt Instruments (IPDI) qualified for deduction under s.36(1)(iii), recognizing these hybrid instruments as legitimate business borrowings despite their perpetual nature and discretionary payout features. The ruling primarily followed established banking sector precedents and emphasized substance over form.
ITAT ruled favorably on multiple issues for the banking assessee. The tribunal allowed deduction under s.36(1)(viia) for NPA provisions, holding them equivalent to provisions for bad and doubtful debts. For s.14A disallowance, matter was remanded to examine administrative expenses allocation despite interest-free funds exceeding investments. Deduction under s.36(1)(vii) was permitted following prior precedent. RBI penalty payment was deemed allowable under s.37 as not being for legal infraction. Interest on Innovative Perpetual Debt Instruments (IPDI) qualified for deduction under s.36(1)(iii), recognizing these hybrid instruments as legitimate business borrowings despite their perpetual nature and discretionary payout features. The ruling primarily followed established banking sector precedents and emphasized substance over form.
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