Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
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Interest on loans advanced from borrowed funds may remain taxable as income from other sources where the statutory basis invoked for business income applies only to termination or modification of an agency or management contract, and no such contract is established. Revenue cannot replace that basis with a general business-income provision by taking a different stand. Interest expenditure on borrowings used to advance loans generating taxable interest is deductible under section 57(iii) where a reasonable and proximate nexus with earning that income is established. Actual income generation in the same year is not required, and an alleged breach of Companies Rules does not by itself defeat the deduction.
Interest on loans advanced from borrowed funds may remain taxable as income from other sources where the statutory basis invoked for business income applies only to termination or modification of an agency or management contract, and no such contract is established. Revenue cannot replace that basis with a general business-income provision by taking a different stand. Interest expenditure on borrowings used to advance loans generating taxable interest is deductible under section 57(iii) where a reasonable and proximate nexus with earning that income is established. Actual income generation in the same year is not required, and an alleged breach of Companies Rules does not by itself defeat the deduction.
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