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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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
Note: It is a system-generated summary and is for quick reference only.
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