Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT allowed the assessee's claim for interest expense deduction under Section 36(1)(iii) regarding funds borrowed through debenture issuance for land purchase. The assessee temporarily invested idle funds in mutual funds and fixed deposits during a seven-day interim period between fund raising and land payment. The tribunal held this constituted an adventure in the nature of business under Section 2(13), undertaken for commercial expediency to offset interest costs rather than capital appreciation. However, ITAT directed partial disallowance under Section 14A for interest expenses attributable to investments yielding exempt dividend income of INR 4,54,581 from the total interest expense of INR 1,56,06,164. The assessing officer must provide reasonable hearing opportunity and allow the remaining deduction after Section 14A disallowance calculations.
ITAT allowed the assessee's claim for interest expense deduction under Section 36(1)(iii) regarding funds borrowed through debenture issuance for land purchase. The assessee temporarily invested idle funds in mutual funds and fixed deposits during a seven-day interim period between fund raising and land payment. The tribunal held this constituted an adventure in the nature of business under Section 2(13), undertaken for commercial expediency to offset interest costs rather than capital appreciation. However, ITAT directed partial disallowance under Section 14A for interest expenses attributable to investments yielding exempt dividend income of INR 4,54,581 from the total interest expense of INR 1,56,06,164. The assessing officer must provide reasonable hearing opportunity and allow the remaining deduction after Section 14A disallowance calculations.
Note: It is a system-generated summary and is for quick reference only.