Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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ITAT Decision: Infrastructure Project Tax Deduction Dispute The ITAT partially allowed the revenue's appeal, addressing multiple taxation issues. The Tribunal upheld deductions for interest income from fixed deposits directly linked to infrastructure project financing, rejecting revenue's challenge. The Tribunal recognized the business expediency of interest-free advances to a subsidiary for project development, dismissing proportionate interest expense disallowance. Concession fee was deemed allowable on accrual basis, consistent with prior rulings. However, guarantee commission income was disallowed under section 80IA, being considered unrelated to core airport infrastructure operations. The Tribunal directed the Assessing Officer to verify specific quantum of expenditures and make appropriate adjustments, essentially providing a nuanced resolution balancing taxpayer's claims and statutory interpretations.
ITAT Decision: Infrastructure Project Tax Deduction Dispute The ITAT partially allowed the revenue's appeal, addressing multiple taxation issues. The Tribunal upheld deductions for interest income from fixed deposits directly linked to infrastructure project financing, rejecting revenue's challenge. The Tribunal recognized the business expediency of interest-free advances to a subsidiary for project development, dismissing proportionate interest expense disallowance. Concession fee was deemed allowable on accrual basis, consistent with prior rulings. However, guarantee commission income was disallowed under section 80IA, being considered unrelated to core airport infrastructure operations. The Tribunal directed the Assessing Officer to verify specific quantum of expenditures and make appropriate adjustments, essentially providing a nuanced resolution balancing taxpayer's claims and statutory interpretations.
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