Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Interest on borrowed capital is deductible under section 36(1)(iii) only when the borrowing is for the assessee's own business or profession. Where the borrowed funds were invested by an individual as capital contribution in a partnership firm, and the business was carried on by the firm rather than by the individual, the statutory condition was not met. The claim, if available at all, would arise at the level of the firm and not in the individual partner's assessment. The deduction was therefore rightly disallowed, and the appeal was dismissed.
Interest on borrowed capital is deductible under section 36(1)(iii) only when the borrowing is for the assessee's own business or profession. Where the borrowed funds were invested by an individual as capital contribution in a partnership firm, and the business was carried on by the firm rather than by the individual, the statutory condition was not met. The claim, if available at all, would arise at the level of the firm and not in the individual partner's assessment. The deduction was therefore rightly disallowed, and the appeal was dismissed.
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