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Income Tax : Interest income earned by a foreign bank from foreign currency loans extended to Indian corporates was taxable on a gross basis. S...
Income Tax : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : ITAT upheld taxation of IPS and CEV subsidies following the Section 2(24) amendment, while partly allowing the appeal on other iss...
Income Tax : ITAT held that Accounting Standard-19 governs accounting treatment but does not determine tax treatment under the Income-tax Act. ...
Income Tax : The ITAT Mumbai held that Explanation 1 to Section 37(1) could not apply in the absence of any finding by the competent authority ...
19. First we will marshal the facts of the present case. The assessee had availed terms loans from three banks, viz. ICICI Bank Ltd., Standard Chartered Bank Ltd. and Sumitomo Mitsui Banking Corporation (SMBC), Hong Kong. These terms loans were availed by the assessee company for the purpose of acquiring capital assets necessarily to be deployed in the manufacturing system
