Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
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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