Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Disallowance of claim of interest expenses u/s. 57(iii) - The Assessing Officer (AO) had disallowed a portion of the interest expenses based on the difference between the interest charged by the appellant on loans given and the interest paid on loans taken. However, the ITAT found that since the appellant used interest-bearing funds to earn interest income, the disallowance of expenses exceeding the interest charged on loans given was not justified. - The Tribunal also criticized the AO's interpretation of the term "income," stating that as long as the expenses were incurred for the purpose of earning income, regardless of whether a profit was earned, they should be allowed as deductions under Section 57(iii) of the Act.
Disallowance of claim of interest expenses u/s. 57(iii) - The Assessing Officer (AO) had disallowed a portion of the interest expenses based on the difference between the interest charged by the appellant on loans given and the interest paid on loans taken. However, the ITAT found that since the appellant used interest-bearing funds to earn interest income, the disallowance of expenses exceeding the interest charged on loans given was not justified. - The Tribunal also criticized the AO's interpretation of the term "income," stating that as long as the expenses were incurred for the purpose of earning income, regardless of whether a profit was earned, they should be allowed as deductions under Section 57(iii) of the Act.
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