Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
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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