Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Claim of Loss - Deduction u/s. 57 - Taxability of real income / net interest income - The Tribunal observed that the investment in perpetual debt instruments (PDIs) was financed by secured debentures. It was established that the funds raised through debentures were not meant for investment in PDIs but for the objectives of the company. The Tribunal allowed the deduction of interest expenditure against interest income, considering only the net income liable for taxation. - ITAT emphasized that only real income, subject to the provisions of the Act, is taxable.
Claim of Loss - Deduction u/s. 57 - Taxability of real income / net interest income - The Tribunal observed that the investment in perpetual debt instruments (PDIs) was financed by secured debentures. It was established that the funds raised through debentures were not meant for investment in PDIs but for the objectives of the company. The Tribunal allowed the deduction of interest expenditure against interest income, considering only the net income liable for taxation. - ITAT emphasized that only real income, subject to the provisions of the Act, is taxable.
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