TMI Blog2013 (2) TMI 874X X X X Extracts X X X X X X X X Extracts X X X X ..... Income Tax Appellate Tribunal ( the Tribunal for short) dated 30.03.2012 raising three questions for our consideration. 2. First question pertains to the decision of the Tribunal in allowing the TDS credit on discounting the charges. We, however, notice that the Tribunal, in the impugned order, observed as under: 2.1.6 The second aspect involved is regarding TDS on bills discounting charge ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unilaterally reversed the entries pertaining to delayed payment charges in November, 2004. Later on, Government of Gujarat worked out formula and provided waiver of delayed payment charges in the following manner: 100% waiver to be made by all IPPS upto 31st March 2000 40% waiver to be made upto 31st March,2005 No waiver with effect from 1st April 2005. 1. On such basis, the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... such issue in the context of deduction under Section 80HHC of the Act has been settled. It is held that it would only be the net of the interest excluding the expenditure incurred in earning such interest income which should be excluded for the purpose of under Section 80 HHC of the Act. To our mind, same would apply even when the revenue desirous to exclude certain interest income from the deduc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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