https://www.taxtmi.com/caselaws?id=122816 Section 263 revision was challenged on the footing that the interest on delayed remittance of U.S. withholding taxes required factual examination before any disallowance under section 40(a)(ii) or denial of the alternative section 10A claim. The record was found insufficient to conclusively determine whether the impugned interest was an accretion to tax or whether part of the remittance related to social security, medicare and similar welfare-related amounts. Additional grounds and supporting materials were admitted because they went to the root of the characterization issue. The matter was therefore remitted for de novo consideration, with the revision order not being sustained on the existing record. en-us Wed, 26 Aug 2009 00:00:00 +0530 Sat, 07 Oct 2023 11:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122816 Section 263 revision was challenged on the footing that the interest on delayed remittance of U.S. withholding taxes required factual examination before any disallowance under section 40(a)(ii) or denial of the alternative section 10A claim. The record was found insufficient to conclusively determine whether the impugned interest was an accretion to tax or whether part of the remittance related to social security, medicare and similar welfare-related amounts. Additional grounds and supporting materials were admitted because they went to the root of the characterization issue. The matter was therefore remitted for de novo consideration, with the revision order not being sustained on the existing record. Case-Laws Income Tax Wed, 26 Aug 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122816