Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Interest on borrowings used to acquire or maintain controlling interests through strategic investments may qualify as business expenditure where the taxpayer's objects, investment pattern, conduct and disclosures establish that strategic investment is part of its business. The business-purpose requirement extends beyond immediate profit generation; dividend being taxed under another head or investments not producing direct business receipts does not by itself defeat deductibility where commercial expediency exists. Separately, where available interest-free funds exceed investments and interest-free advances, investments are presumed to have been made from those funds. Absence of a direct fund-wise nexus therefore does not justify disallowing interest on borrowings.
Interest on borrowings used to acquire or maintain controlling interests through strategic investments may qualify as business expenditure where the taxpayer's objects, investment pattern, conduct and disclosures establish that strategic investment is part of its business. The business-purpose requirement extends beyond immediate profit generation; dividend being taxed under another head or investments not producing direct business receipts does not by itself defeat deductibility where commercial expediency exists. Separately, where available interest-free funds exceed investments and interest-free advances, investments are presumed to have been made from those funds. Absence of a direct fund-wise nexus therefore does not justify disallowing interest on borrowings.
Note: It is a system-generated summary and is for quick reference only.
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