Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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ITAT allowed the appeal of the anonymous partnership assessee, holding that interest paid on delayed remittance of GST and VAT is compensatory rather than penal in nature and therefore deductible for income-tax purposes. The Tribunal found that the payment was made to discharge statutory liabilities and not to punish the assessee, placing it within the ambit of allowable business expenditure. Accordingly, the grounds challenging disallowance of such interest were allowed and the addition was deleted, with the assessment adjusted to reflect the deduction of interest on delayed statutory remittances.
ITAT allowed the appeal of the anonymous partnership assessee, holding that interest paid on delayed remittance of GST and VAT is compensatory rather than penal in nature and therefore deductible for income-tax purposes. The Tribunal found that the payment was made to discharge statutory liabilities and not to punish the assessee, placing it within the ambit of allowable business expenditure. Accordingly, the grounds challenging disallowance of such interest were allowed and the addition was deleted, with the assessment adjusted to reflect the deduction of interest on delayed statutory remittances.
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