Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displa...
Final benami adjudication bars contradictory tax-evasion prosecution where settlement findings confirm full disclosure and cooperation without conceal...
Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
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 
TaxTMI 
of 4891 
