Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Revision u/s 263 - addition on account of notional interest @10% on deposit - The High court upheld the concurrent findings of the ITAT and the CIT(A) that no notional interest income accrued to the assessee, after its amalgamation, as per the loan agreement clause. - This decision was based on the principle that income cannot be taxed on a purely notional basis; it must either accrue as per agreement terms or be received by the assessee.
Revision u/s 263 - addition on account of notional interest @10% on deposit - The High court upheld the concurrent findings of the ITAT and the CIT(A) that no notional interest income accrued to the assessee, after its amalgamation, as per the loan agreement clause. - This decision was based on the principle that income cannot be taxed on a purely notional basis; it must either accrue as per agreement terms or be received by the assessee.
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