Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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ITAT held that interest on fixed deposits and related receipts were taxable as income from other sources because the maintenance clauses in the sale deed and co-developer agreement did not create diversion of income by overriding title; the funds and accrued interest remained under the assessee's control, so the use of interest for maintenance was only application of income after accrual. It also held that maintenance and administrative did not have the direct and exclusive nexus required for deduction against such interest income, so the disallowance was sustained. However, the Tribunal accepted that a claim under section 80P(2)(d) could not be denied merely because the return was filed under section 139(4), and directed allowance after hearing.
ITAT held that interest on fixed deposits and related receipts were taxable as income from other sources because the maintenance clauses in the sale deed and co-developer agreement did not create diversion of income by overriding title; the funds and accrued interest remained under the assessee's control, so the use of interest for maintenance was only application of income after accrual. It also held that maintenance and administrative did not have the direct and exclusive nexus required for deduction against such interest income, so the disallowance was sustained. However, the Tribunal accepted that a claim under section 80P(2)(d) could not be denied merely because the return was filed under section 139(4), and directed allowance after hearing.
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