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HC affirms AT and revenue findings, holding that receipt of Rs. 66,00,000 from the company constitutes salary, not professional/business income, because the assessee failed to produce documentary evidence specifying nature or nexus of professional/technical services rendered. The court found a conflict of interest where loans advanced to the company were in the assessee's name, undermining the professional-fee characterization; TDS treatment as "professional charges" is not determinative of income heads. Further, interest expenditure of Rs. 45,26,956 is disallowed for lack of nexus with any business or profession of the assessee; mortgaging and advancing personal property to the company does not render the interest an allowable business expense. Appeal dismissed; decision for Revenue.
HC affirms AT and revenue findings, holding that receipt of Rs. 66,00,000 from the company constitutes salary, not professional/business income, because the assessee failed to produce documentary evidence specifying nature or nexus of professional/technical services rendered. The court found a conflict of interest where loans advanced to the company were in the assessee's name, undermining the professional-fee characterization; TDS treatment as "professional charges" is not determinative of income heads. Further, interest expenditure of Rs. 45,26,956 is disallowed for lack of nexus with any business or profession of the assessee; mortgaging and advancing personal property to the company does not render the interest an allowable business expense. Appeal dismissed; decision for Revenue.
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