Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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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