Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4794
Join Channel
TaxTMI 
