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2012 (9) TMI 147 - AT - Income TaxCompensation paid to lender treated as interest - Disallowance for non deduction of TDS u/s 194A - Expenditure must be accrued or paid/payable in the current year - Held that:- Explanation to Section 194A r.w.s. 2(28A) provides that when such interest is credited in any account by whatever name it may be called, then such credit will be deemed to be credit of such income to the account of the payee and provisions of Section 194A will apply - Liability for payment has neither accrued nor paid/payable in the current year therefore disallowed and added back - Decided in favor of Revenue. Deduction allowed for expenditure u/s 14A - Computation of book profit under MAT u/s 115JB - Held that:- The provision of section 14A cannot be imported into while computing the book profit u/s 115JB of the Act as decided in case of Goetze (India) Ltd. 2009 (5) TMI 615 - ITAT DELHI - Therefore no addition to the book profit shall be made on account of alleged expenditure incurred to earn exempt income while computing income u/s 115JB of the Act - Decided in favor of Assessee
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