Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Disallowance of interest u/s 40A - The unsecured borrowings by a commercial organisation like the assessee, on these facts, @ 16% interest seems to be reasonable. The benchmark @ 14% adopted by the ld. CIT(A), by taking fixed deposit interest rates of companies like MGF Limited and Rama Vision Ltd., cannot be applied in a rigid way. - AT
Disallowance of interest u/s 40A - The unsecured borrowings by a commercial organisation like the assessee, on these facts, @ 16% interest seems to be reasonable. The benchmark @ 14% adopted by the ld. CIT(A), by taking fixed deposit interest rates of companies like MGF Limited and Rama Vision Ltd., cannot be applied in a rigid way. - AT
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