Juridical seat versus arbitral venue determines supervisory court jurisdiction, while timely award challenges remain within the prescribed limitation ...
Tax deduction at source on interest arises on credit or payment, whichever occurs first; a brought-forward interest liability does not itself constitute a current-year credit. The real income doctrine requires objectively established contemporaneous circumstances showing that income did not accrue, rather than merely an absence of accounting entries. Unexplained-expenditure provisions apply to expenditure incurred in the relevant financial year and do not extend to an earlier capital advance merely carried forward, particularly where recorded in regular books. A capital work-in-progress write-off already added back in computing business income should not be added again, as this would result in double taxation. Interest capitalised to work-in-progress is not subject to disallowance where tax was deducted and deposited within the prescribed return-filing timeline.
Tax deduction at source on interest arises on credit or payment, whichever occurs first; a brought-forward interest liability does not itself constitute a current-year credit. The real income doctrine requires objectively established contemporaneous circumstances showing that income did not accrue, rather than merely an absence of accounting entries. Unexplained-expenditure provisions apply to expenditure incurred in the relevant financial year and do not extend to an earlier capital advance merely carried forward, particularly where recorded in regular books. A capital work-in-progress write-off already added back in computing business income should not be added again, as this would result in double taxation. Interest capitalised to work-in-progress is not subject to disallowance where tax was deducted and deposited within the prescribed return-filing timeline.
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