Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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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