Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Revision under revisional jurisdiction challenged the deductibility of provisions for 'standard assets' claimed as bad and doubtful debts under the income tax deduction provision for banks. The Tribunal analysed the RBI Master Direction definition of standard assets and construed the deduction provision, noting conflicting coordinate bench decisions but following consistent precedents that allow provisions for standard assets. Applying those precedents, the Tribunal quashed the revisional proceedings insofar as they sought to disallow the provision and restored the assessment outcome favourable to the assessee for the relevant year.
Revision under revisional jurisdiction challenged the deductibility of provisions for 'standard assets' claimed as bad and doubtful debts under the income tax deduction provision for banks. The Tribunal analysed the RBI Master Direction definition of standard assets and construed the deduction provision, noting conflicting coordinate bench decisions but following consistent precedents that allow provisions for standard assets. Applying those precedents, the Tribunal quashed the revisional proceedings insofar as they sought to disallow the provision and restored the assessment outcome favourable to the assessee for the relevant year.
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