Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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Deduction of interest expenditure incurred on borrowed funds u/s 57 - Interest incurred on borrowed funds utilized for making investment in shares in company of Singapore - The ITAT considered the purpose of the investment, emphasizing that the investment was made to earn future income. It referred to a similar case decided by the Calcutta High Court, which held that expenditure on interest could be allowable under Section 57 even if the investment was not solely for earning dividends. The Tribunal concluded that since the investment was made to generate income, the interest expenditure should be allowed as a deduction.
Deduction of interest expenditure incurred on borrowed funds u/s 57 - Interest incurred on borrowed funds utilized for making investment in shares in company of Singapore - The ITAT considered the purpose of the investment, emphasizing that the investment was made to earn future income. It referred to a similar case decided by the Calcutta High Court, which held that expenditure on interest could be allowable under Section 57 even if the investment was not solely for earning dividends. The Tribunal concluded that since the investment was made to generate income, the interest expenditure should be allowed as a deduction.
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