Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
The tribunal addressed deductibility of interest expenditure claimed under Income from Other Sources, applying the intention-and-nexus test: expenditure is deductible if laid out wholly and exclusively for earning that income. Factually, borrowings were advanced as loans that generated interest income, confirmations, ledger entries and income computation established a proximate nexus, and remand proceedings produced no adverse finding on genuineness. CIT(A)s disallowance for lack of documentary linkage was held unsustainable. Reliance on precedent affirming intent over actual earning was distinguished as inapplicable here because income was in fact earned and taxed; the appeal allowing the deduction was allowed.
The tribunal addressed deductibility of interest expenditure claimed under Income from Other Sources, applying the intention-and-nexus test: expenditure is deductible if laid out wholly and exclusively for earning that income. Factually, borrowings were advanced as loans that generated interest income, confirmations, ledger entries and income computation established a proximate nexus, and remand proceedings produced no adverse finding on genuineness. CIT(A)s disallowance for lack of documentary linkage was held unsustainable. Reliance on precedent affirming intent over actual earning was distinguished as inapplicable here because income was in fact earned and taxed; the appeal allowing the deduction was allowed.
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