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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 fixed deposits subject to prohibitory orders and pending criminal proceedings was held not taxable on accrual because, under the real income principle and the governing circular, income arises only when receipt is sufficiently certain. The fact that the assessee had earlier offered the interest on accrual basis, or that TDS may have been deducted, did not make the uncredited interest taxable while entitlement to the deposits remained uncertain. The court added that if the assessee is ultimately held entitled to the deposits, appropriate additions may then be made. The Tribunal's deletion of the accrued-interest addition was upheld.
Interest on fixed deposits subject to prohibitory orders and pending criminal proceedings was held not taxable on accrual because, under the real income principle and the governing circular, income arises only when receipt is sufficiently certain. The fact that the assessee had earlier offered the interest on accrual basis, or that TDS may have been deducted, did not make the uncredited interest taxable while entitlement to the deposits remained uncertain. The court added that if the assessee is ultimately held entitled to the deposits, appropriate additions may then be made. The Tribunal's deletion of the accrued-interest addition was upheld.
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