Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Deduction u/s 57 was disallowed for interest income from savings bank account and interest from Thangamayil Jewellery Limited, classified under "other sources". The issue was whether a direct nexus existed between the loan borrowed and loan given. The names on loan documents did not match the assessee's name, and deductions u/s 57 were denied as the loans were for specific purposes like home and agriculture. However, relying on ACIT vs. Nishith Desai, the Tribunal allowed interest expenditure deduction u/s 57, as it was wholly and exclusively for earning interest income, following CIT vs. Rajendra Prasad Moody. Lack of evidence like bank statements showing loan credit to Thangamayil Jewellery Limited necessitated remanding the matter to the Assessing Officer for fresh examination. The assessee was directed to file evidence for the claim u/s 57. The appeal was allowed for statistical purposes.
Deduction u/s 57 was disallowed for interest income from savings bank account and interest from Thangamayil Jewellery Limited, classified under "other sources". The issue was whether a direct nexus existed between the loan borrowed and loan given. The names on loan documents did not match the assessee's name, and deductions u/s 57 were denied as the loans were for specific purposes like home and agriculture. However, relying on ACIT vs. Nishith Desai, the Tribunal allowed interest expenditure deduction u/s 57, as it was wholly and exclusively for earning interest income, following CIT vs. Rajendra Prasad Moody. Lack of evidence like bank statements showing loan credit to Thangamayil Jewellery Limited necessitated remanding the matter to the Assessing Officer for fresh examination. The assessee was directed to file evidence for the claim u/s 57. The appeal was allowed for statistical purposes.
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