Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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