Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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...
Page of 4792
Press 'Enter' after typing page number.
461 to 480 of 95833 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Disallowance of interest difference between the rate paid on borrowed capital and the rate advanced to a wholly owned subsidiary is not warranted. The Supreme Court in S.A. Builders held that advancing funds by a holding company to its subsidiary for commercial expediency does not warrant disallowance of interest, even if not charged. The Delhi Tribunal in Moonrock Hospitality ruled that where funds were advanced to a wholly owned subsidiary for business purposes, no interest paid on borrowed funds could be disallowed u/s 36(1)(iii) of the Income Tax Act. Following these precedents, the Tribunal held that no disallowance of interest paid on borrowed funds was permissible and directed the Assessing Officer to delete the addition.
Disallowance of interest difference between the rate paid on borrowed capital and the rate advanced to a wholly owned subsidiary is not warranted. The Supreme Court in S.A. Builders held that advancing funds by a holding company to its subsidiary for commercial expediency does not warrant disallowance of interest, even if not charged. The Delhi Tribunal in Moonrock Hospitality ruled that where funds were advanced to a wholly owned subsidiary for business purposes, no interest paid on borrowed funds could be disallowed u/s 36(1)(iii) of the Income Tax Act. Following these precedents, the Tribunal held that no disallowance of interest paid on borrowed funds was permissible and directed the Assessing Officer to delete the addition.
Note: It is a system-generated summary and is for quick reference only.