Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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