Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
The ITAT upheld that recovery of bad debts not previously claimed as deduction under section 36(1)(vii) is not taxable and directed deletion of related additions. It allowed deduction of interest on Innovative Perpetual Debt Instruments under section 36(1)(iii) and disallowed taxation of accrued but not due interest, consistent with established precedents. The Tribunal confirmed that foreign branch profits are taxable in India with credit for foreign taxes and rejected the assessee's claim for exclusion under section 90. Disallowances related to FCTR losses, write-offs of bad debts, compensatory payments, doubtful debts, broken period interest, amortisation of premium on HTM securities, and section 14A disallowance were set aside. The AO was directed to amend assessments accordingly.
The ITAT upheld that recovery of bad debts not previously claimed as deduction under section 36(1)(vii) is not taxable and directed deletion of related additions. It allowed deduction of interest on Innovative Perpetual Debt Instruments under section 36(1)(iii) and disallowed taxation of accrued but not due interest, consistent with established precedents. The Tribunal confirmed that foreign branch profits are taxable in India with credit for foreign taxes and rejected the assessee's claim for exclusion under section 90. Disallowances related to FCTR losses, write-offs of bad debts, compensatory payments, doubtful debts, broken period interest, amortisation of premium on HTM securities, and section 14A disallowance were set aside. The AO was directed to amend assessments accordingly.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
