Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
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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