Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
A bona fide change from the mercantile to the cash system for interest on loans may be permissible where it serves a legitimate purpose, is consistently followed, duly disclosed, and is not intended to avoid or reduce tax liability. The notes state that financial distress of the borrower and non-receipt of accrued interest supported the change, while the Revenue produced no material showing lack of legitimacy or frequent switching of methods. As the assessment record acknowledged use of the cash method, the change was treated as disclosed, and the addition for accrued but unrealised interest was deleted.
A bona fide change from the mercantile to the cash system for interest on loans may be permissible where it serves a legitimate purpose, is consistently followed, duly disclosed, and is not intended to avoid or reduce tax liability. The notes state that financial distress of the borrower and non-receipt of accrued interest supported the change, while the Revenue produced no material showing lack of legitimacy or frequent switching of methods. As the assessment record acknowledged use of the cash method, the change was treated as disclosed, and the addition for accrued but unrealised interest was deleted.
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