Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Interest on capital borrowed for business purposes is deductible, subject to the restriction applicable until an acquired asset is first put to use. Use of land as a storage yard may be established through delivery and transport records, electricity bills and photographs; such evidence requires verification and cannot be rejected without contrary material. Construction reflected as capital work-in-progress on part of the land does not by itself show that the remaining land was not used for business. Where interest-free funds and borrowings form a common pool, investment is presumed to come from interest-free funds unless a direct nexus with interest-bearing borrowings is established.
Interest on capital borrowed for business purposes is deductible, subject to the restriction applicable until an acquired asset is first put to use. Use of land as a storage yard may be established through delivery and transport records, electricity bills and photographs; such evidence requires verification and cannot be rejected without contrary material. Construction reflected as capital work-in-progress on part of the land does not by itself show that the remaining land was not used for business. Where interest-free funds and borrowings form a common pool, investment is presumed to come from interest-free funds unless a direct nexus with interest-bearing borrowings is established.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
