Addition on interest expenditure - principle of “consistency” - ...

Case Laws Income Tax

August 9, 2023

Addition on interest expenditure - principle of “consistency” - interest in the nature of penalty - when on identical facts, the Department has not made any disallowance in respect of interest payments, which the assessee has been consistently paying over a period of 10 years i.e. both in the past years as well as for the future assessment years, then the Department is precluded from making disallowance on the same set of facts in the impugned year under consideration. - AT

View Source

← Previous Next →

Addition on interest expenditure - principle of “consistency” - ...

Case Laws Income Tax

August 9, 2023

You may also like:

Disallowance of interest expenditure u/s 57 - nexus between the interest income vis-à-vis the interest expenditure - no nexus between the impugned income and interest...

Penalty 271(1)(c) - deduction of interest out of ‘income from other sources’ - The AO has admitted the claim of interest expenditure to the extent of interest income and...

Imposition of penalty u/s 271(1)(c) of the Income Tax Act for two types of additions: (1) the addition made u/s 50C on the difference between stamp duty value and sale...

Income from other sources - Deduction of interest expenditure - direction of the CIT – A in restricting the deduction to the extent of income earned of term deposit -...

Penalty u/s 271(1)(c) - Disallowance of interest expenditure under section 43B as well as disallowance export product development expenses - Just because the assessee...

Estimation of notional interest income for making the disallowance out of interest expenditure - The ld. AO ought to have not over emphasized about the conduct of the...

Disallowance of interest u/s 36(1)(iii) towards interest expenditure - allegation that assessee company diverted its “interest bearing funds” for giving “interest free...

Interest expenses claim against the interest income received - It is the nature of the business and all the expenditure incurred in earning the income is allowable...

Addition u/s 57(iii) - Interest expenditure - monies borrowed at a higher rate of interest - it is established that the interest expenditure is linked to the interest...

Principle of consistency - There is a significant value which must attach to observing the requirement of consistency and certainty. Individual affairs are conducted and...

Addition u/s 69A - Addition of cash deposits made by the assessee during the demonetization period - The Tribunal examined the legality of the assessment order, the...

Interest earned on deposit - principle of mutuality - The interest earned on such deposit has a clear and direct nexus to the expenditure incurred in the form of...

Penalty u/s 271(1)(c) - when we examine penalty levied on account of salary disallowance AO has merely made adhoc addition by way of guess work and the AO has not...

Nature of expenditure - fertility improvement program amongst milk animals - The expenditure was general in nature and to be allowed as revenue expenditure.

If expenditure incurred by the assessee are in the nature of annual maintenance contracts, then such expenditure certainly are in the nature of revenue expenditure - AT

Quick Updates: