Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Addition of interest attributable on the diversion of loan fund - Once own fund of the assessee exceeds the amount of interest free loans and advances, then a presumption can be drawn that the interest free loans and advances has been given by the assessee out of its own interest free fund available with it. Thus, in such a situation the disallowance of interest u/s 36(1)(iii) is not warranted. - AT
Addition of interest attributable on the diversion of loan fund - Once own fund of the assessee exceeds the amount of interest free loans and advances, then a presumption can be drawn that the interest free loans and advances has been given by the assessee out of its own interest free fund available with it. Thus, in such a situation the disallowance of interest u/s 36(1)(iii) is not warranted. - AT
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