International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
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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