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...
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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