Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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