Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Disallowance of interest u/s. 36(1)(iii) - loan borrowed for the purpose of settling outgoing partners’ capital account - The settlement of capital account of outgoing partners becomes debt of partnership firm and discharge of said debt out of borrowed funds assumes the character of loans/funds borrowed for the purpose of business of the assessee. - interest paid on borrowed capital account is allowable deduction u/s. 36(1)(iii) of the Act. - AT
Disallowance of interest u/s. 36(1)(iii) - loan borrowed for the purpose of settling outgoing partners’ capital account - The settlement of capital account of outgoing partners becomes debt of partnership firm and discharge of said debt out of borrowed funds assumes the character of loans/funds borrowed for the purpose of business of the assessee. - interest paid on borrowed capital account is allowable deduction u/s. 36(1)(iii) of the Act. - AT
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