Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
ITAT held that interest on unsecured loans was correctly disallowed under section 36(1)(iii). The assessee failed to substantiate the genuineness and creditworthiness of loan transactions. Mere routing of interest through banking channels or TDS deduction does not prove loan legitimacy. The tribunal found no credible documentary evidence to establish the identity of lenders or loan authenticity. The assessee's inability to provide repayment details or demonstrate commercial substance of loans justified the disallowance of interest expenditure. The decision reinforces the principle that deduction of interest is contingent upon proving a genuine and subsisting business liability. Ultimately, the appeal was decided against the assessee, upholding the lower authorities' findings.
ITAT held that interest on unsecured loans was correctly disallowed under section 36(1)(iii). The assessee failed to substantiate the genuineness and creditworthiness of loan transactions. Mere routing of interest through banking channels or TDS deduction does not prove loan legitimacy. The tribunal found no credible documentary evidence to establish the identity of lenders or loan authenticity. The assessee's inability to provide repayment details or demonstrate commercial substance of loans justified the disallowance of interest expenditure. The decision reinforces the principle that deduction of interest is contingent upon proving a genuine and subsisting business liability. Ultimately, the appeal was decided against the assessee, upholding the lower authorities' findings.
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