ITAT Ahmedabad allows Interest expenses even if interest rate charged by the assessee on loans given was lower than the rate paid on loans taken, thus disallowing the excess interest paid. Tribunal held that the only requirement for claiming expenses under Section 57(iii) is that they must be incurred wholly and exclusively for the purpose of earning income from other sources.
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Section 271D penalty proceeding cannot be initiated if AO fail to record his satisfaction before initiating penalty penalty proceeding in respect of violation of provisions of section 269SS of Income Tax Act, 1961.
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Tribunal ruled that mere disallowance of expenses or enhancement of returned income does not automatically warrant the imposition of penalties under Section 271(1)(c)
ITAT considered the justification provided by the assessee, which referenced KITCO and Reuters databases for determining transaction prices. However, the Transfer Pricing Officer (TPO) argued that the London Bullion Market Association (LBMA) should be the primary source for estimating bullion trading prices.
