ITAT Delhi held that addition of interest income on fixed deposit with Canara Bank sustainable as contention of the assessee that fixed deposit is misplaced and hence there is no question of earning any interest income is illogical.
Section 54F exemption would be granted to assessee on its residential properties and assessee cannot be said to have not ‘Purchased’ properties for not having sale deed executed in its favour.
ITAT Delhi held that shortfall in interest adjusted from principal amount on principle of first appropriation towards interest before principal. Then, assessee being in lending business, the shortage towards principal is allowable as bad debt.
ITAT Delhi held that as per specific provisions covered under section 178(6), Insolvency and Bankruptcy Code, 2016 has an overriding effect on all the acts including Income Tax Act.
ITAT Delhi held that assessment order passed in violation of the directions of Dispute Resolution Penal (DRP) is against the provisions of sub-section (10) and (13) of section 144C of the Act and hence liable to be quashed
ITAT Delhi held that property sold is to be taxed under Capital gain as the property was held for considerable longer period of time and assessee is not engaged into systemic real estate business activity.
Distribution revenue earned by assessee had already offered income as business income in terms of the Mutual Agreement Procedure (MAP) holding that 10% of the advertising and subscription revenue received from India should be deemed to be the net profit chargeable to tax in India, therefore, the additions made by AO were deleted.
ITAT Delhi held that disallow of any interest expenditure u/s 14A r.w. Rule 8D of the Act unsustainable as the interest bearing funds borrowed by the assessee have not been utilized for making the investments.
ITAT Delhi held that social security contribution doesnt constitute income from salary in the hands of expatriate employees. Hence disallowance u/s 40(ia) for non-deduction of TDS on the same is unsustainable in law.
Assessee was unable to furnish any cogent explanation supported by evidence to establish that the consultancy charges paid are not in the nature of FTS.
