Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
Classification of imported goods as electronic cigarette versus tobacco product reversed for lack of proof; order set aside for jurisdictional overrea...
On fresh examination of the capital bond agreement, the ITAT found that clause 5 created a binding obligation on the assessee to pay accrued interest to Prestige. Because the bond funds were provided by Prestige and the related interest income had been assessed in the assessee's hands, the corresponding interest liability was deductible as an allowable expenditure. The earlier view that no enforceable obligation existed was rejected, and the disallowance of interest paid to Prestige was directed to be deleted. The appeals were allowed to that extent.
On fresh examination of the capital bond agreement, the ITAT found that clause 5 created a binding obligation on the assessee to pay accrued interest to Prestige. Because the bond funds were provided by Prestige and the related interest income had been assessed in the assessee's hands, the corresponding interest liability was deductible as an allowable expenditure. The earlier view that no enforceable obligation existed was rejected, and the disallowance of interest paid to Prestige was directed to be deleted. The appeals were allowed to that extent.
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