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Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
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Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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