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(2)(ii) was held impermissible because the assessee established availability of surplus own funds for making investments yielding exempt income; hence no interest disallowance could be attributed to such investments, and the disallowance was deleted. Disallowance under Rule 8D(2)(iii) was held untenable absent the AO's recorded objective satisfaction, as mandated by s.14A and settled law; the direction to recompute based on proper satisfaction was sustained. Sales tax and power subsidies were treated as capital receipts since the dominant purpose was industrial development and employment generation; addition to book profit u/s 115JB was rejected. Additional depreciation and bad-debt write-off/provision treatment (including under MAT) were allowed, and carry-forward of amalgamating company's LTC loss was upheld per the approved amalgamation scheme, resulting in dismissal of Revenue's grounds and partial dismissal of assessee's appeal. - ITAT
Disallowance under s.14A r.w. Rule 8D(2)(ii) was held impermissible because the assessee established availability of surplus own funds for making investments yielding exempt income; hence no interest disallowance could be attributed to such investments, and the disallowance was deleted. Disallowance under Rule 8D(2)(iii) was held untenable absent the AO's recorded objective satisfaction, as mandated by s.14A and settled law; the direction to recompute based on proper satisfaction was sustained. Sales tax and power subsidies were treated as capital receipts since the dominant purpose was industrial development and employment generation; addition to book profit u/s 115JB was rejected. Additional depreciation and bad-debt write-off/provision treatment (including under MAT) were allowed, and carry-forward of amalgamating company's LTC loss was upheld per the approved amalgamation scheme, resulting in dismissal of Revenue's grounds and partial dismissal of assessee's appeal. - ITAT
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