Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Interest on borrowings used to acquire plant, machinery, scrap, land and buildings held as current assets for sale in an asset-trading business is revenue expenditure. The proviso to section 36(1)(iii), which restricts interest deduction until an acquired asset is first put to use, does not apply where the assets are acquired solely for resale and are neither intended nor required to be used in manufacturing. Borrowings for buying and selling such assets are for business purposes. Acquisition-related expenses incurred in dealing in current assets for sale are likewise revenue expenditure allowable under section 37(1), rather than capital expenditure.
Interest on borrowings used to acquire plant, machinery, scrap, land and buildings held as current assets for sale in an asset-trading business is revenue expenditure. The proviso to section 36(1)(iii), which restricts interest deduction until an acquired asset is first put to use, does not apply where the assets are acquired solely for resale and are neither intended nor required to be used in manufacturing. Borrowings for buying and selling such assets are for business purposes. Acquisition-related expenses incurred in dealing in current assets for sale are likewise revenue expenditure allowable under section 37(1), rather than capital expenditure.
Note: It is a system-generated summary and is for quick reference only.
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