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The ITAT dismissed the assessee's DTAA beneficial-rate challenge, following the Special Bench; held the appointed date in the amalgamation scheme is effective from 01.01.2018 so BFIL's rural advances post-that date qualify for deduction under s.36(1)(viia) with 8.5% applicable, but remitted quantum to the AO for factual verification; remitted the issue of loss on sale of property acquired in satisfaction of debt to AO to examine facts and allow as business loss; directed AO to examine and allow s.36(1)(viia) claims for provisions on standard assets; remitted additional ESOP deduction for verification; deleted s.14A disallowance; upheld allowability of QIP issue expenses under s.35D; allowed credit-card bad debts under s.36(1)(vii); sustained deduction for interest on perpetual bonds and amortisation of HTM premium; broken-period interest decision favours the assessee.
The ITAT dismissed the assessee's DTAA beneficial-rate challenge, following the Special Bench; held the appointed date in the amalgamation scheme is effective from 01.01.2018 so BFIL's rural advances post-that date qualify for deduction under s.36(1)(viia) with 8.5% applicable, but remitted quantum to the AO for factual verification; remitted the issue of loss on sale of property acquired in satisfaction of debt to AO to examine facts and allow as business loss; directed AO to examine and allow s.36(1)(viia) claims for provisions on standard assets; remitted additional ESOP deduction for verification; deleted s.14A disallowance; upheld allowability of QIP issue expenses under s.35D; allowed credit-card bad debts under s.36(1)(vii); sustained deduction for interest on perpetual bonds and amortisation of HTM premium; broken-period interest decision favours the assessee.
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