Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Commercial expediency of interest-free advances to a wholly owned subsidiary should be assessed from the perspective of a prudent businessman, without substituting the Revenue's commercial judgment. The note addresses deduction of interest on borrowed funds advanced to a special purpose vehicle formed to acquire land for group business operations. Documentary evidence of the subsidiary's land-acquisition purpose, subsequent lease of the land for the proposed business, and a board-approved start-up interest holiday supports the business purpose of the advance. Delay in completing land-acquisition formalities does not, by itself, negate that purpose. Interest expenditure under section 36(1)(iii) is described as allowable, with the disallowance deleted.
Commercial expediency of interest-free advances to a wholly owned subsidiary should be assessed from the perspective of a prudent businessman, without substituting the Revenue's commercial judgment. The note addresses deduction of interest on borrowed funds advanced to a special purpose vehicle formed to acquire land for group business operations. Documentary evidence of the subsidiary's land-acquisition purpose, subsequent lease of the land for the proposed business, and a board-approved start-up interest holiday supports the business purpose of the advance. Delay in completing land-acquisition formalities does not, by itself, negate that purpose. Interest expenditure under section 36(1)(iii) is described as allowable, with the disallowance deleted.
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