Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
Explanation 4 to section 11 prevents loan-funded expenditure from being treated as application of income when the borrowing is deployed, but permits the repayment to qualify in the year of repayment if that amount was not already allowed. On the record, the charitable trust had excluded borrowed sums from application in the years of borrowing and claimed application only on repayment, and the Revenue did not rebut the supporting accounts, returns or statements. As no earlier double claim was shown, the repayment was treated as valid application of income and the disallowance was deleted.
Explanation 4 to section 11 prevents loan-funded expenditure from being treated as application of income when the borrowing is deployed, but permits the repayment to qualify in the year of repayment if that amount was not already allowed. On the record, the charitable trust had excluded borrowed sums from application in the years of borrowing and claimed application only on repayment, and the Revenue did not rebut the supporting accounts, returns or statements. As no earlier double claim was shown, the repayment was treated as valid application of income and the disallowance was deleted.
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