Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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ITAT affirmed that the assessee is entitled to deductions under both s.36(1)(vii) and s.36(1)(viia)(c), holding the proviso to s.36(1)(vii) merely caps bad-debt write-offs by the credit balance in provisions to prevent double deduction; factual review showed no excess or duplication, so CIT(A)'s allowance was upheld. On s.14A, the Tribunal directed the AO to confine disallowance to the assessee's suo-motu pro-rata allocation to investment-department costs, rejecting the AO's challenge absent specific contrary accounting findings. Deductions under s.36(1)(viii) were held independent of s.36(1)(viia)(c) computations. The amortised rent issue was remitted to the AO for reconsideration under s.158A upon Form-8 compliance.
ITAT affirmed that the assessee is entitled to deductions under both s.36(1)(vii) and s.36(1)(viia)(c), holding the proviso to s.36(1)(vii) merely caps bad-debt write-offs by the credit balance in provisions to prevent double deduction; factual review showed no excess or duplication, so CIT(A)'s allowance was upheld. On s.14A, the Tribunal directed the AO to confine disallowance to the assessee's suo-motu pro-rata allocation to investment-department costs, rejecting the AO's challenge absent specific contrary accounting findings. Deductions under s.36(1)(viii) were held independent of s.36(1)(viia)(c) computations. The amortised rent issue was remitted to the AO for reconsideration under s.158A upon Form-8 compliance.
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