<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2026 (8) TMI 1166 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=797292</link>
    <description>Section 56(2)(viib) does not apply where shares are allotted as non-cash consideration for acquiring a business undertaking, because no money is received on issue. Receivables previously recognised as income and written off after non-recovery qualify as bad debts; student receivables cannot be partly disallowed on an unsupported ad hoc basis. No section 14A disallowance arises without exempt income. Reversal of unearned fees and related prepaid franchise fees is not taxable under sections 41(1) or 28(iv) without prior deduction or benefit. Loan processing charges are deductible business expenditure. Recipient taxation protects royalty payments from disallowance. Prior-period expenses require proof of crystallisation, while verification is required for claimed voluntary disallowance of expense provisions.</description>
    <language>en-us</language>
    <pubDate>Wed, 05 Aug 2026 00:00:00 +0530</pubDate>
    <lastBuildDate>Thu, 20 Aug 2026 08:14:29 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=917964" rel="self" type="application/rss+xml"/>
    <item>
      <title>2026 (8) TMI 1166 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=797292</link>
      <description>Section 56(2)(viib) does not apply where shares are allotted as non-cash consideration for acquiring a business undertaking, because no money is received on issue. Receivables previously recognised as income and written off after non-recovery qualify as bad debts; student receivables cannot be partly disallowed on an unsupported ad hoc basis. No section 14A disallowance arises without exempt income. Reversal of unearned fees and related prepaid franchise fees is not taxable under sections 41(1) or 28(iv) without prior deduction or benefit. Loan processing charges are deductible business expenditure. Recipient taxation protects royalty payments from disallowance. Prior-period expenses require proof of crystallisation, while verification is required for claimed voluntary disallowance of expense provisions.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Wed, 05 Aug 2026 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=797292</guid>
    </item>
  </channel>
</rss>