Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Income From other sources - The Appellate Tribunal addressed the disallowance of interest expenses u/s 57(iii) of the Act. The claim was denied due to lack of direct nexus between the interest expenditure and income from other sources. The assessee argued that the borrowed amount was invested in firms where they earned interest income and in immovable properties. The Tribunal noted that u/s 57(iii), expenditure must be incurred "wholly and exclusively" for earning such income. As there was no clear correlation between the expenditure and interest income, the CIT(A) rightly disallowed the interest expenditure. Since none of the expenditure was solely for earning income, it could not be allowed u/s 57(iii). Consequently, the appeal was dismissed.
Income From other sources - The Appellate Tribunal addressed the disallowance of interest expenses u/s 57(iii) of the Act. The claim was denied due to lack of direct nexus between the interest expenditure and income from other sources. The assessee argued that the borrowed amount was invested in firms where they earned interest income and in immovable properties. The Tribunal noted that u/s 57(iii), expenditure must be incurred "wholly and exclusively" for earning such income. As there was no clear correlation between the expenditure and interest income, the CIT(A) rightly disallowed the interest expenditure. Since none of the expenditure was solely for earning income, it could not be allowed u/s 57(iii). Consequently, the appeal was dismissed.
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