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2021 (9) TMI 1340 - AT - Income TaxRectification of mistake u/s 154 - Addition of towards allocation of interest expenses towards dividend income, under the head business income - HELD THAT:- Since, the assessee has also raised additional ground No. 2, towards allocation of interest expenses towards dividend income which is not academics as noted by the Tribunal. We are of the view that once it is held that the investment giving rise to dividend income were made out of interest free funds, the disallowance of interest expenditure while computing profits and gains of business was not justified. Hence, we are of the view that this interest expenditure need to be allowed. We direct the Assessing Officer accordingly. This mistake is rectified. Treatment of sales Tax incentive and fertilizer subsidy as income eligible for claiming of deduction under section 80IB - HELD THAT:- We noted that the facts relating to the issue whether the sales tax incentives or fertilizers subsidy is capital receipt or revenue receipt, the adjudication by Tribunal is not there. Even, the facts are not dealt with by the Tribunal in its order. Hence, without commenting on the facts, we recall the order of the Tribunal on this issue and direct the registry to fix this appeal.
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