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ITAT allowed in part and remitted several issues for fresh...
Appeal partly allowed; notional interest and warranty disallowance remitted; s.36(1)(iii) reconsidered; s.40(a)(ia) upheld; s.14A sustained to extent of exempt income
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ITAT allowed in part and remitted several issues for fresh fact-finding. The addition of notional interest on receivables from associated enterprises is set aside and remitted to the TPO for re-examination of comparative credit periods and quantification vis-Ã -vis non-AEs. The warranty provision disallowance is remitted to the AO for de novo scrutiny of documentary evidence and accounting treatment. The assessment under s.36(1)(iii) is remitted to the AO to consider the assessee's own-funds position and apply relevant authority. The disallowance under s.14A is directed to be sustained only to the extent of exempt income. The s.40(a)(ia) disallowance is upheld. Listing fees for NCD issuance are held allowable.
ITAT allowed in part and remitted several issues for fresh fact-finding. The addition of notional interest on receivables from associated enterprises is set aside and remitted to the TPO for re-examination of comparative credit periods and quantification vis-Ã -vis non-AEs. The warranty provision disallowance is remitted to the AO for de novo scrutiny of documentary evidence and accounting treatment. The assessment under s.36(1)(iii) is remitted to the AO to consider the assessee's own-funds position and apply relevant authority. The disallowance under s.14A is directed to be sustained only to the extent of exempt income. The s.40(a)(ia) disallowance is upheld. Listing fees for NCD issuance are held allowable.
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