Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Employee conflict disclosures and investment restrictions expand with new recusal duties, post-employment limits, and compliance reporting requirement...
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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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