Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT adjudicated a tax dispute concerning interest income from a non-performing debt. The tribunal determined that no interest income could be recognized when the debtor was declared an NPA and undergoing insolvency proceedings. The key legal principle established was that taxation must be based on realistic income probability, not hypothetical earnings. The tribunal upheld the lower appellate authority's decision, rejecting the assessee's claim to recognize interest income on an accrual basis. Additionally, the tribunal denied TDS credit since no corresponding income was declared, citing precedent that TDS cannot be claimed without corresponding income recognition. The order effectively deleted the interest amount of Rs. 3,60,00,000/- and dismissed the assessee's grounds for TDS credit.
ITAT adjudicated a tax dispute concerning interest income from a non-performing debt. The tribunal determined that no interest income could be recognized when the debtor was declared an NPA and undergoing insolvency proceedings. The key legal principle established was that taxation must be based on realistic income probability, not hypothetical earnings. The tribunal upheld the lower appellate authority's decision, rejecting the assessee's claim to recognize interest income on an accrual basis. Additionally, the tribunal denied TDS credit since no corresponding income was declared, citing precedent that TDS cannot be claimed without corresponding income recognition. The order effectively deleted the interest amount of Rs. 3,60,00,000/- and dismissed the assessee's grounds for TDS credit.
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