Condonation of delay in filing GSTR-3B returns and entitlement to Section 62 benefit results in withdrawal of assessments and revocation of attachment...
Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
