Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
Dominant issue: classification of interest receipts as business income - applying the definition of "business" and principles of consistency, the tribunal found the taxpayer systematically raised large unsecured borrowings, intermediated loans through brokers, operated with profit motive and attendant risks, thereby satisfying all ingredients of business activity; interest was hence held to be income from business (appeal dismissed on this point). Subsidiary issues: disallowance under section 40(a)(ia) - because interest was business expenditure and TDS under section 194A was not deducted, the deduction was disallowed (ground dismissed); compliance with section 44AB - business receipts exceeded statutory threshold and an audit was required (ground dismissed). - ITAT
Dominant issue: classification of interest receipts as business income - applying the definition of "business" and principles of consistency, the tribunal found the taxpayer systematically raised large unsecured borrowings, intermediated loans through brokers, operated with profit motive and attendant risks, thereby satisfying all ingredients of business activity; interest was hence held to be income from business (appeal dismissed on this point). Subsidiary issues: disallowance under section 40(a)(ia) - because interest was business expenditure and TDS under section 194A was not deducted, the deduction was disallowed (ground dismissed); compliance with section 44AB - business receipts exceeded statutory threshold and an audit was required (ground dismissed). - ITAT
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