Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Interest liability accrued on a soft loan advanced by the State Government under an agreement was disallowed as an unascertained liability under section 37. Applying the mercantile system, interest became payable and had to be provided in the accounts notwithstanding that repayment had not commenced due to non-withdrawal of the full sanctioned amount. Since the loan was admittedly obtained and interest was contractually chargeable, the interest provision constituted an ascertained liability and could not be disallowed under section 37. The deduction for interest so provided was directed to be allowed, and the appeal was allowed. - ITAT
Interest liability accrued on a soft loan advanced by the State Government under an agreement was disallowed as an unascertained liability under section 37. Applying the mercantile system, interest became payable and had to be provided in the accounts notwithstanding that repayment had not commenced due to non-withdrawal of the full sanctioned amount. Since the loan was admittedly obtained and interest was contractually chargeable, the interest provision constituted an ascertained liability and could not be disallowed under section 37. The deduction for interest so provided was directed to be allowed, and the appeal was allowed. - ITAT
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