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 section 14A/Rule 8D: Rule 8D disallowance must be computed only with reference to investments that actually yielded exempt income, and AO is directed to recompute disallowance at 1% of the monthly average of those exempt-income-yielding investments - disallowance restricted accordingly. Disallowance added to book profit u/s 115JB: Clause (f) of Explanation 1 to s.115JB is to be computed without applying s.14A/Rule 8D, therefore the 14A addition to book profit is deleted. Interest on borrowings for interest-free advances: where own non-interest funds cover advances, no disallowance of borrowed interest - addition deleted. Vastu payments/depreciation: recurring large payments not for business purpose - addition upheld (disallowed). Government subsidy: treated as income under amended law - appeal dismissed. Royalty: deductible only on actual payment under s.43B - confirmed. Leave-encashment provision for 115JB: remitted to AO to decide under Explanation (1). Interest on belated TDS: allowed in computing book profit. 80IA transfer-pricing adjustment: deleted. SBN deposits u/s 68: remitted to AO for verification; matter allowed for statistical purposes. - ITAT
Disallowance under section 14A/Rule 8D: Rule 8D disallowance must be computed only with reference to investments that actually yielded exempt income, and AO is directed to recompute disallowance at 1% of the monthly average of those exempt-income-yielding investments - disallowance restricted accordingly. Disallowance added to book profit u/s 115JB: Clause (f) of Explanation 1 to s.115JB is to be computed without applying s.14A/Rule 8D, therefore the 14A addition to book profit is deleted. Interest on borrowings for interest-free advances: where own non-interest funds cover advances, no disallowance of borrowed interest - addition deleted. Vastu payments/depreciation: recurring large payments not for business purpose - addition upheld (disallowed). Government subsidy: treated as income under amended law - appeal dismissed. Royalty: deductible only on actual payment under s.43B - confirmed. Leave-encashment provision for 115JB: remitted to AO to decide under Explanation (1). Interest on belated TDS: allowed in computing book profit. 80IA transfer-pricing adjustment: deleted. SBN deposits u/s 68: remitted to AO for verification; matter allowed for statistical purposes. - ITAT
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