Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Page of 4792
Press 'Enter' after typing page number.
121 to 140 of 95833 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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 4792
Join Channel
TaxTMI 
