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Interest on customers' fixed deposits was held deductible because the taxpayer produced contemporaneous evidence of deposits and TDS, and mere absence of payee-side acknowledgement could not justify disallowance; deletion was sustained. Disallowance under s.14A r.w. Rule 8D was held inapplicable as the investments were maintained for SLR/CRR as stock-in-trade, following binding precedent; deletion was sustained. Depreciation on temporary wooden structures and software expenditure were treated as allowable (as per consistency with earlier years); disallowances were rejected. Inter-office adjustment provision was treated as an allowable anticipated liability supported by material, not a contingent/non-existent liability; disallowance was rejected. Deduction u/s 36(1)(viia) was directed to be allowed on total provision (rural and non-rural). Depreciation on G-Secs, HTM premium amortization loss, and provision for non-performing investments were allowed. - ITAT
Interest on customers' fixed deposits was held deductible because the taxpayer produced contemporaneous evidence of deposits and TDS, and mere absence of payee-side acknowledgement could not justify disallowance; deletion was sustained. Disallowance under s.14A r.w. Rule 8D was held inapplicable as the investments were maintained for SLR/CRR as stock-in-trade, following binding precedent; deletion was sustained. Depreciation on temporary wooden structures and software expenditure were treated as allowable (as per consistency with earlier years); disallowances were rejected. Inter-office adjustment provision was treated as an allowable anticipated liability supported by material, not a contingent/non-existent liability; disallowance was rejected. Deduction u/s 36(1)(viia) was directed to be allowed on total provision (rural and non-rural). Depreciation on G-Secs, HTM premium amortization loss, and provision for non-performing investments were allowed. - ITAT
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