Foreign portfolio investment liberalisation extends listed equity access to all individual persons resident outside India, subject to limit monitoring...
Unsubstantiated exempt agricultural income claim sustains concealment penalty after disclosure only on departmental detection and no bona fide evidenc...
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ITAT held that processing fees, upfront fees, lead financer fees, security trustee fees and similar receipts arising from sanctioning, structuring and administering long-term loans had a direct nexus with the assessee's long-term finance business and were eligible for deduction under section 36(1)(viii). It further held that pre-closure of loans did not alter the character of loans sanctioned for repayment over not less than five years, so deduction could not be denied merely because borrowers prepaid earlier. The Tribunal sustained remand on the interest-income issue because factual verification was still required on double taxation. It also affirmed that section 14A disallowance under Rule 8D applies only to investments yielding exempt income, and upheld deduction under section 80G for CSR donations.
ITAT held that processing fees, upfront fees, lead financer fees, security trustee fees and similar receipts arising from sanctioning, structuring and administering long-term loans had a direct nexus with the assessee's long-term finance business and were eligible for deduction under section 36(1)(viii). It further held that pre-closure of loans did not alter the character of loans sanctioned for repayment over not less than five years, so deduction could not be denied merely because borrowers prepaid earlier. The Tribunal sustained remand on the interest-income issue because factual verification was still required on double taxation. It also affirmed that section 14A disallowance under Rule 8D applies only to investments yielding exempt income, and upheld deduction under section 80G for CSR donations.
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