Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
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 ...
Interest expenditure on borrowings used to make interest-bearing unsecured advances is deductible against taxable interest income under section 57 where the nexus is established. The Assessing Officer's findings showed that the advances to private parties were funded through interest-bearing loans from banks and non-banking financial companies. As the borrowing cost was directly connected with earning the interest income assessed under income from other sources, the disallowance was deleted for the relevant assessment years.
Interest expenditure on borrowings used to make interest-bearing unsecured advances is deductible against taxable interest income under section 57 where the nexus is established. The Assessing Officer's findings showed that the advances to private parties were funded through interest-bearing loans from banks and non-banking financial companies. As the borrowing cost was directly connected with earning the interest income assessed under income from other sources, the disallowance was deleted for the relevant assessment years.
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