Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
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Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
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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