The ITAT partially allowed the assessee's appeal against ...

Interest on PFC Loans Disallowed Under Section 43B While Bonus Payment and Capital Grants Write-backs Upheld

March 13, 2025

Case Laws Income Tax AT

The ITAT partially allowed the assessee's appeal against revision under section 263. Regarding bonus payment of Rs. 2.02 crores, the Tribunal found that the AO had properly examined this issue during assessment proceedings, and the assessee had demonstrated payment before the return filing due date in compliance with section 43B. However, concerning interest expenses on PFC loans amounting to Rs. 17.91 crores, the Tribunal upheld the PCIT's finding that the AO erred in allowing unpaid interest without proper examination, violating section 43B requirements. On the third issue of Capital Grants & Subsidies and Consumer Contribution write-backs, the Tribunal rejected the PCIT's contention of shortfall, accepting the assessee's demonstration that the correct amounts were properly accounted for.

View Source

← Previous Next →

The ITAT partially allowed the assessee's appeal against ...

Interest on PFC Loans Disallowed Under Section 43B While Bonus Payment and Capital Grants Write-backs Upheld

March 13, 2025

Case Laws Income Tax AT

You may also like:

Characterization of income - cash receipt due to waiver of loan by the state government - whether in the nature of subsidy - to be treated as benefit / perquisite u/s...

Bad debts - Writing off of Loan to farmers - The treatment of the write-offs of such loans would then have to be viewed probably as bad debts, though this may not be...

Assessment of notional interest on loans - loan has been granted by the assessee to its sister concern - As per the provisions of Sec. 36(1)(iii) AO could have...

Disallowance of interest relating to Capital Work in Progress (CWIP) - The Appellant has furnished the relevant working capital facility agreements and ledger account to...

Deemed dividend u/s 2(22)(e) is not taxable in the hands of the assessee company if it is not a shareholder in the companies that extended loans. It is chargeable to tax...

Disallowance on interest u/s. 36(1)(iii) - AO has compared the payment of interest @ 12%/15% on the unsecured loan obtained by the assessee with the interest amount...

Addition towards undisclosed income being write back of redeemable non cumulative preference shares - write back of preference share capital cannot be taxed u/s 28(iv)...

TP Adjustment - Interest on interest outstanding/interest receivable - The interest on a loan is a compensation received towards the utilisation of funds given by the...

Allowability of capital loss as well as the right of deferred tax assets - Disallowance of capital expenditure debited to the profit and loss account - whether CIT-A...

Key legal issues and the Tribunal's holdings: Agricultural land sold by assessee situated beyond municipal limits cannot be treated as capital asset u/s 2(14). Addition...

Unsecured loans treated as unexplained cash credits u/s 68. Interest paid on such unexplained loans also added to income. Assessee's contention of repayment of loans...

TP adjustment of interest - CIT(A) confirmed upward adjustment towards interest by adopting rupee loan rate instead of LIBOR linked rate in respect of foreign currency...

Real estate development company advanced loans to its Indian subsidiary for funding step-down foreign subsidiaries undertaking real estate projects. Interest paid on...

Rental income - Deduction u/s 24(b) - interest paid on the amount borrowed - the loan was not borrowed for the impugned Flat No.11. Assessee had claimed that the loan...

The ITAT held that deduction of interest u/s 57 against interest income must be substantiated by the assessee. Interest expenditure must be incurred for earning interest...

Quick Updates: