Income Tax : We find that there is no concept of deferred revenue expenditure under the Income Tax Act except under certain specific, provision...
Income Tax : Section 194A (3) (b) Imposes duty on a co-operative society engaged in banking to deduct TDS where amount exceeds Rs. 10,000/-, wh...
Income Tax : It is a general presumption that, expenditure in acquisition of assets is a capital expenditure there by not eligible for deductio...
Income Tax : The decision of the case is based on the verdict by Apex Court of India in the case of TRF Limited Vs CIT, [323 ITR 397 (SC)] Wher...
Income Tax : If the investments are not made from borrowed funds, then there should not be any disallowance. Since in this case it was evidence...
We find that there is no concept of deferred revenue expenditure under the Income Tax Act except under certain specific, provisions like section 35D. Therefore, unless statutory provision is there to defer the revenue expenditure over a period
Section 194A (3) (b) Imposes duty on a co-operative society engaged in banking to deduct TDS where amount exceeds Rs. 10,000/-, whereas section 194A (3) (v) grants specific exemption to cooperative societies where payment made by it to members or to another co-operative society.
It is a general presumption that, expenditure in acquisition of assets is a capital expenditure there by not eligible for deduction u/s 37 (1) of the IT Act (However depreciation is allowed as per IT Rules) The honorable CIT (A) failed to note the difference in the nature of the soft-wares as dealt in Maruti Udyog Ltd. vs Deputy Commissioner Of Income Tax
The decision of the case is based on the verdict by Apex Court of India in the case of TRF Limited Vs CIT, [323 ITR 397 (SC)] Where Honorable Court has held that, it is not necessary for the assessee to establish that the debt, in fact, has become irrecoverable.
If the investments are not made from borrowed funds, then there should not be any disallowance. Since in this case it was evidenced from the records and evidence s that the income accured was from internal accruals consequently addition deleted
The first arguments which has been considered was regarding the source of advances in the 100% subsidiary comapy, which the assessee company argued to be out of reservs and suplus, which could not be contradicted by the Revenue.
