Processing & Upfront Fees Eligible for Deduction Due to Direct Nexus with Financing Business: ITAT Delhi

REC Limited Vs ACIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, adjudicated cross appeals filed by the assessee and the Revenue for Assessment Years (AYs) 2018–19 and 2019–20, along with Revenue appeals for AYs 2020–21 and 2021–22. Since the issues were common across years, the Tribunal disposed of all appeals through a consolidated order. Core Issue: Deduction under Section 36(1)(viii) The principal dispute revolved around the allowability and computation of deduction under Section 36(1)(viii), which permits specified entities to claim deduction up to 20% of profits ...