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...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
The ITAT held that interest paid under Section 50(3) of the GST Act is compensatory, not penal, and thus deductible under Section 37(1) of the Income Tax Act. The disallowance of such interest by the AO and CIT(A) was set aside. Regarding disallowance under Section 36(1)(iii) for interest on advances, the Tribunal found no established nexus between borrowed funds and interest-free advances, relying on the presumption that advances were made from interest-free funds supported by financial statements. The AO's reliance on statements without proper fund tracing was insufficient. Consequently, the disallowance under Section 36(1)(iii) was also deleted.
The ITAT held that interest paid under Section 50(3) of the GST Act is compensatory, not penal, and thus deductible under Section 37(1) of the Income Tax Act. The disallowance of such interest by the AO and CIT(A) was set aside. Regarding disallowance under Section 36(1)(iii) for interest on advances, the Tribunal found no established nexus between borrowed funds and interest-free advances, relying on the presumption that advances were made from interest-free funds supported by financial statements. The AO's reliance on statements without proper fund tracing was insufficient. Consequently, the disallowance under Section 36(1)(iii) was also deleted.
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