Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Disallowance under the interest-attributable rule is held unsustainable where shares are held as stock-in-trade; amortisation of lease premium is capital in nature, with depreciation to be allowed. Income of overseas branches is includible in Indian taxable income, with foreign tax credit available to the extent admissible under applicable tax treaties and domestic credit rules; computation must follow treaty and local law for credit purposes. Deductions for bad debts written off and amortisation of HTM losses are allowed; broken period interest on securities held as stock-in-trade is revenue expenditure; interest on NPAs not recognised until credited or received; loss on sale to ARC is allowable; penalty for regulatory breach by foreign branch is nondeductible under business expense rules.
Disallowance under the interest-attributable rule is held unsustainable where shares are held as stock-in-trade; amortisation of lease premium is capital in nature, with depreciation to be allowed. Income of overseas branches is includible in Indian taxable income, with foreign tax credit available to the extent admissible under applicable tax treaties and domestic credit rules; computation must follow treaty and local law for credit purposes. Deductions for bad debts written off and amortisation of HTM losses are allowed; broken period interest on securities held as stock-in-trade is revenue expenditure; interest on NPAs not recognised until credited or received; loss on sale to ARC is allowable; penalty for regulatory breach by foreign branch is nondeductible under business expense rules.
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