Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
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 4894 
