Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
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 ...
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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