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Income Tax - Highlights / Catch Notes

Home Highlights November 2023 Year 2023 This

Accrual of income - Taxability of income - interest income ...

Income Tax

November 9, 2023

Accrual of income - Taxability of income - interest income generated on the funds received from Gol - ownership of Interest earned - Since the entire amounts received as interest stands deposited in the consolidated fund of India, we hold that no addition is called for in the hands of the assessee. - AT

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  1. Accrual of income - taxability of advances received - Merely because an amount has been entered into in assessee’s book, is not conclusive proof that income has accrued - AT

  2. Taxability of Interest earned on funds - belong to the assessee or not - amount / funds contributed by subsidiaries towards the shifting and rehabilitation fund - the...

  3. Gain from conversion of currency - accrual of income - Use of repatriated funds – entire funds were raised abroad - no addition - HC

  4. Interest income from temporary advancement of funds - interest received by the assessee cannot be treated as income from business and it has to be treated as income...

  5. Taxability of interest on FD received from bank - concept of mutuality -the income cannot be said to have been derived from any activity based on principle of mutuality - HC

  6. Interest on refund of income tax received by the PE of the assessee - taxability - applicability of Article 12(5) or Article 12(2) of DTAA between India and France - not...

  7. Taxability of income from transfer of development rights - postponement of payment does not stop accrual of income - AT

  8. Taxability in hands of society - fund transferred to ‘Distribution Pool Fund Account’ it is not taxable in the hands of the Society. - SC

  9. Accrual of income on Kisan Vikas Patra - Promissory note OR not - the interest on Kisaan Vikas Patras has to be assessed to income tax on accrual basis - HC

  10. Taxability - research projects - educational programs - The case involved disputes regarding the taxability of fees for a post-graduate program and externally funded...

 

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