Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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