Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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For unsecured loans, the notes state that before 1 April 2023, section 68 did not require an assessee to establish the source of a lender's funds, except for credits such as share application money, share capital or share premium. Based on remand reports accepting confirmations, creditworthiness and genuineness, the Tribunal treated the loans as genuine, deleted the section 68 additions and allowed related interest. For interest-free advances, where partners' capital and other non-interest-bearing funds exceeded advances to group concerns, no interest disallowance under section 36(1)(iii) was warranted. The related disallowances were deleted and all appeals were allowed.
For unsecured loans, the notes state that before 1 April 2023, section 68 did not require an assessee to establish the source of a lender's funds, except for credits such as share application money, share capital or share premium. Based on remand reports accepting confirmations, creditworthiness and genuineness, the Tribunal treated the loans as genuine, deleted the section 68 additions and allowed related interest. For interest-free advances, where partners' capital and other non-interest-bearing funds exceeded advances to group concerns, no interest disallowance under section 36(1)(iii) was warranted. The related disallowances were deleted and all appeals were allowed.
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