Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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ITAT held that where interest on unsecured loans was genuinely incurred for business purposes, the dispute could be confined only to the year of allowability under the mercantile system. As no finding was recorded that the interest was bogus, non-business, or lacking bona fides, disallowance of the portion claimed in the relevant year could not be sustained merely because it might be deductible in the next year. Shifting the deduction period was treated as revenue neutral, and the addition for alleged excess interest expenditure was deleted.
ITAT held that where interest on unsecured loans was genuinely incurred for business purposes, the dispute could be confined only to the year of allowability under the mercantile system. As no finding was recorded that the interest was bogus, non-business, or lacking bona fides, disallowance of the portion claimed in the relevant year could not be sustained merely because it might be deductible in the next year. Shifting the deduction period was treated as revenue neutral, and the addition for alleged excess interest expenditure was deleted.
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