Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
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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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