https://www.taxtmi.com/caselaws?id=792000 Where an investment in a wholly owned subsidiary had already been disallowed in the return, a further assessment addition was treated as a double disallowance; the write-off was held to be incidental to business and the addition was deleted. Broken period interest on debentures was excluded because the debentures were sold before the interest fell due and the same economic receipt was already embedded in later capital gains, avoiding double taxation. The DTAA dividend-rate claim for non-resident shareholders required fresh factual verification and was remanded. Initiation of penalty proceedings under section 270A was held premature and the challenge failed. en-us Mon, 18 May 2026 00:00:00 +0530 Thu, 21 May 2026 08:30:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792000 Where an investment in a wholly owned subsidiary had already been disallowed in the return, a further assessment addition was treated as a double disallowance; the write-off was held to be incidental to business and the addition was deleted. Broken period interest on debentures was excluded because the debentures were sold before the interest fell due and the same economic receipt was already embedded in later capital gains, avoiding double taxation. The DTAA dividend-rate claim for non-resident shareholders required fresh factual verification and was remanded. Initiation of penalty proceedings under section 270A was held premature and the challenge failed. Case-Laws Income Tax Mon, 18 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792000