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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Interest credited under a partnership deed may be allowable when calculated on daily running credit balances, even if opening and closing capital-account balances are debit balances and the credit is recorded through year-end journal entries under the mercantile system. The notes state that detailed account workings, contractual authorisation, recipient income recognition and tax deduction at source negate allegations of fictitious expenditure or income diversion; the related disallowance was deleted. Interest expenditure credited to a lender is also described as not disallowable where Form 16A evidences tax deduction and the recipient has recognised and returned the income; banking-channel payment is not stated to be required for accrued interest. The appeal was partly allowed.
Interest credited under a partnership deed may be allowable when calculated on daily running credit balances, even if opening and closing capital-account balances are debit balances and the credit is recorded through year-end journal entries under the mercantile system. The notes state that detailed account workings, contractual authorisation, recipient income recognition and tax deduction at source negate allegations of fictitious expenditure or income diversion; the related disallowance was deleted. Interest expenditure credited to a lender is also described as not disallowable where Form 16A evidences tax deduction and the recipient has recognised and returned the income; banking-channel payment is not stated to be required for accrued interest. The appeal was partly allowed.
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