Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
