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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Advances given to 5 persons without charging interest were for business purposes. Non-installation of machinery or renovation in subsequent period due to non-viability cannot negate the business purpose. Assessee decided not to proceed with its plan due to bad market condition, which is a valid business decision and consequential expenditure cannot be disallowed. Assessee had sufficient interest-free capital exceeding the interest-free advances, hence disallowance of interest is impermissible as per jurisdictional High Court precedents.
Advances given to 5 persons without charging interest were for business purposes. Non-installation of machinery or renovation in subsequent period due to non-viability cannot negate the business purpose. Assessee decided not to proceed with its plan due to bad market condition, which is a valid business decision and consequential expenditure cannot be disallowed. Assessee had sufficient interest-free capital exceeding the interest-free advances, hence disallowance of interest is impermissible as per jurisdictional High Court precedents.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
