Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Disallowance under s.14A r/w Rule 8D was held inapplicable where dividend-yielding shares were held as stock-in-trade; no proximate expenditure was established, so the disallowance was deleted. Exclusion of foreign branch profits was rejected; instead, treaty-based foreign tax credit (FTC) was to be granted upon verification of foreign taxes paid, non-claim earlier, and DTAA admissibility, and computed jurisdiction-wise; the issue was restored to the AO for limited verification. Carried-forward FTC for prior-year foreign taxes was allowed where the corresponding foreign income became taxable in India only when losses were set off; AO to cap credit to domestic tax incidence and verify, with remand. MAT under s.115JB was held inapplicable to the assessee bank. Deduction under s.36(1)(viia) was directed to be computed before set-off of brought-forward losses. Refund interest under s.244A directions were upheld. - ITAT
Disallowance under s.14A r/w Rule 8D was held inapplicable where dividend-yielding shares were held as stock-in-trade; no proximate expenditure was established, so the disallowance was deleted. Exclusion of foreign branch profits was rejected; instead, treaty-based foreign tax credit (FTC) was to be granted upon verification of foreign taxes paid, non-claim earlier, and DTAA admissibility, and computed jurisdiction-wise; the issue was restored to the AO for limited verification. Carried-forward FTC for prior-year foreign taxes was allowed where the corresponding foreign income became taxable in India only when losses were set off; AO to cap credit to domestic tax incidence and verify, with remand. MAT under s.115JB was held inapplicable to the assessee bank. Deduction under s.36(1)(viia) was directed to be computed before set-off of brought-forward losses. Refund interest under s.244A directions were upheld. - ITAT
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