Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
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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