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 ...
Allowable deduction of interest paid on the borrowings - Section 14A and Section 36(1)(iii) - Exempted dividend income - Based on the discussions and findings, the court dismissed the appeal, affirming the decision of the ITAT. It upheld the disallowance of the interest expense, considering the provisions of Section 14A and the principles established in the Maxopp Investment Ltd. case. The expenditure incurred on interest paid on borrowed funds for investment in shares of the two companies, from which dividend income does not form part of the total income, was held to be hit by Section 14A of the Act and not allowable as deduction.
Allowable deduction of interest paid on the borrowings - Section 14A and Section 36(1)(iii) - Exempted dividend income - Based on the discussions and findings, the court dismissed the appeal, affirming the decision of the ITAT. It upheld the disallowance of the interest expense, considering the provisions of Section 14A and the principles established in the Maxopp Investment Ltd. case. The expenditure incurred on interest paid on borrowed funds for investment in shares of the two companies, from which dividend income does not form part of the total income, was held to be hit by Section 14A of the Act and not allowable as deduction.
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