Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Deduction under section 57(iii) is available only where the expenditure is incurred wholly and exclusively for earning the relevant income and where a direct and proximate nexus exists between the borrowing and the interest income. On the facts, the assessee failed to prove that link; the record showed use of borrowed funds for share investment and purchase of plots and residential property, and a bare assertion of intent to earn income was insufficient without supporting evidence. The earlier year was distinguishable because direct nexus had then been established. The disallowance of the interest expenditure was therefore upheld.
Deduction under section 57(iii) is available only where the expenditure is incurred wholly and exclusively for earning the relevant income and where a direct and proximate nexus exists between the borrowing and the interest income. On the facts, the assessee failed to prove that link; the record showed use of borrowed funds for share investment and purchase of plots and residential property, and a bare assertion of intent to earn income was insufficient without supporting evidence. The earlier year was distinguishable because direct nexus had then been established. The disallowance of the interest expenditure was therefore upheld.
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