Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
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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