Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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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