Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
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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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