Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
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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