Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
The ITAT dismissed the Revenue's appeals challenging the assessee bank's treatment of amortization of premium on HTM securities, holding it appropriate to amortize over the holding period in line with RBI guidelines. Disallowances relating to depreciation on investments, venture capital fund investments, and MTM derivatives were rejected, reaffirming prior Tribunal and Supreme Court precedents that found no escapement of income. The disallowance of inter-office adjustments was also dismissed, recognizing these as reconciled internal entries. Additions under section 14A read with Rule 8D concerning exempt income were negated following Delhi High Court rulings. Depreciation on goodwill was allowed as an intangible asset under section 32(1). Contributions to the pension fund were upheld as deductible business expenses under section 43B. Finally, the claim under section 36(1)(viii) for advances granted for eligible business purposes was allowed subject to quantification by the AO as directed by the CIT(A).
The ITAT dismissed the Revenue's appeals challenging the assessee bank's treatment of amortization of premium on HTM securities, holding it appropriate to amortize over the holding period in line with RBI guidelines. Disallowances relating to depreciation on investments, venture capital fund investments, and MTM derivatives were rejected, reaffirming prior Tribunal and Supreme Court precedents that found no escapement of income. The disallowance of inter-office adjustments was also dismissed, recognizing these as reconciled internal entries. Additions under section 14A read with Rule 8D concerning exempt income were negated following Delhi High Court rulings. Depreciation on goodwill was allowed as an intangible asset under section 32(1). Contributions to the pension fund were upheld as deductible business expenses under section 43B. Finally, the claim under section 36(1)(viii) for advances granted for eligible business purposes was allowed subject to quantification by the AO as directed by the CIT(A).
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