Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT allowed the assessee-bank's claim for deduction of amortization of premium paid on purchase of government securities held under the HTM category. It held that the assessee, engaged in banking business under the Banking Regulation Act, 1949 and Regional Rural Banks Act, 1976, is statutorily required to invest in government securities to maintain SLR and capital adequacy norms prescribed by RBI. The Tribunal treated the premium amortized over the period to maturity as revenue expenditure, following its earlier precedent, and held that such amortization is an allowable deduction in computing taxable income. The Revenue's objections were consequently rejected.
ITAT allowed the assessee-bank's claim for deduction of amortization of premium paid on purchase of government securities held under the HTM category. It held that the assessee, engaged in banking business under the Banking Regulation Act, 1949 and Regional Rural Banks Act, 1976, is statutorily required to invest in government securities to maintain SLR and capital adequacy norms prescribed by RBI. The Tribunal treated the premium amortized over the period to maturity as revenue expenditure, following its earlier precedent, and held that such amortization is an allowable deduction in computing taxable income. The Revenue's objections were consequently rejected.
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