Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
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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.
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