HC deletes Section 36(1)(viii) disallowance on the principles consistency & certainty

PCIT Vs PNB Housing Finance Ltd (Delhi High Court) Appellant states that the ITAT has erred in deleting the disallowance made under Section 36(1)(viii) of the Income Tax Act, 1961 (‘the Act’) by not considering the total receipt of business for the purpose of working out the proportion to be used in calculating the ratio for deduction under the said provision. He further states that the ITAT has failed to appreciate that total business receipts and not any sector specific receipts are the relevant factor for arriving at the quantum of disallowance under Section 36(1)(viii) of the Act. As r...