Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
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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 ...
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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