Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
