Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Interest income earned from fixed deposits created as margin for availing business loans was rightly treated as business income and netted off against interest expenditure capitalized in work-in-progress (WIP). CIT(A) and coordinate bench for earlier year upheld this treatment based on nexus between interest earned and assessee's business. Decisions relied upon held such interest to be business income, not income from other sources. Assessing Officer failed to establish that fixed deposits were from surplus funds rather than borrowed advances/overdraft facility for business purposes. Assessee established funds were incidental to business activity, hence interest cannot be treated as income from other sources. CIT(A)'s order upheld, decided against revenue.
Interest income earned from fixed deposits created as margin for availing business loans was rightly treated as business income and netted off against interest expenditure capitalized in work-in-progress (WIP). CIT(A) and coordinate bench for earlier year upheld this treatment based on nexus between interest earned and assessee's business. Decisions relied upon held such interest to be business income, not income from other sources. Assessing Officer failed to establish that fixed deposits were from surplus funds rather than borrowed advances/overdraft facility for business purposes. Assessee established funds were incidental to business activity, hence interest cannot be treated as income from other sources. CIT(A)'s order upheld, decided against revenue.
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